Answer:
Neither the SAFE Act nor Reg Z prescribe who should perform the job, only that there be policies and procedures to manage and control it. My recommendation is for compliance to be the primary overseer, with HR as a strong backup. But that does not mean compliance gets involved in personnel matters, such as a deciding what to do about problematic records revealed by a criminal background check. So what should you do? Join the upcoming webinar “MLO, LO, or Neither?” to learn more about how to best adminster your compliance management program for these rules!
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Learn more about Rebekah Leonard’s webinar
MLO, LO, or Neither?