Answer:
The SAFE Act would not require it since you're regulated by the FDIC, provided that the individual in question is an employee of the bank. That individual will have to be registered under the SAFE Act if he or she meets the definition of "mortgage loan originator" in the FDIC's SAFE Act implementing regulations at 12 CFR Part 365, Subpart B.
First published on BankersOnline.com 2/14/11