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Rich Moldenhauer
Flagship Bank Minnesota

 
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9 Documents 4 Answers 10 Exam Watches 12 Vendor Reviews
 
Internal Training Class - Overview SAFE ACT
Contributed by:Compliance/BSA/Legal
Asset size: Bank with under $250m
Location: Midwest
Description: We wanted to document that we offer an "overview" of the SAFE ACT registration process and train new employees on the termonology. Most important was the understanding of "licensed" and "registered" because mortgage loan originators, who work for an insured depository or its owned or controlled subsidiary that is regulated by a federal banking agency, must be registered (not licensed). This is an overview from a bank perspective. I have it placed on our training web site to be assigned to new employees who fall within the guidelines of MLO. There are ten questions at the end of the summary. Answers are included.
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MORE PEER CONTRIBUTED DOCUMENTS:
Safe Act Policy
Contributed by:EVP‚ Compliance/BSA/Legal
Asset size: Bank with between $250m - $500m
Location: Midwest
Description: Safe Act Policy that is comprehensive, but still offers flexibility for you to develop procedures for the SAFE act.
SAFE Act Policy & Procedures
Contributed by:Lending/Credit/Loan Admin
Asset size: Bank with under $250m
Location: Midwest
Description: Standard SAFE Act Policy & Procedures tweaked for a Community Bank
Safe Act
Contributed by:President‚ Compliance/BSA/Legal
Asset size: Bank with under $250m
Location: Midwest
Description: Safe Act Policy
SEE ALL 9 DOCUMENTS >>


RELATED QUESTIONS AND ANSWERS:
Q
SAFE Act Inquiry
Asked by: Risk Management
Asset size: Credit Union with over $1b
Location:PA

Wondering how everyone is addrssing this issue and would appreciate feedback relative to SAFE Act complaince.

Are you allowing customer contact staff to complete mortgage applications in your branches? Do you view them (Tellers, Senior Tellers, etc.) as an "originator" per the terms of the Act? Have they been educated on the Act and other obligations as a Mortgage Loan Originator? Have you registered them with NMLS? What about in your phone centers (in/out)? How do you approach compliance with the Act here?

Curious how others are approaching this issue.
A
Answered by:Risk Management
Asset size: Credit Union with over $1b
Location: PA

Thanks Folks! Appreciate the feedback. Needed to see if my logic was sound following a ...
Q
SAFE Act Procedure Communication with Consumer
Asked by: VP,‚ Audit
Asset size: Bank with under $250m
Location:AL

Would like to some of the methods banks are using to meet the requirements of MLO provision of their unique identifier when communicating with consumers. What is the "first written communication"? And also how MLO unique identifiers are being made available to the public- lobby notice or website?
A
Answered by:VP, ‚ Compliance/BSA/Legal
Asset size: Bank with between $250m - $500m
Location: TX

In the Examination Procedures from the CFPB, it's required that institutions provide MLO ...
SEE ALL 4 ANSWERS >>


RELATED EXAM EXPERIENCES:
FRB - S&S | October 2011
exam experience posted by a from member with under $250m in assets
Audit committee of the board or directors was reduced to only non employee board members. Management no longer is a member of the committee. No adverse findings, just audit indenpendence
FDIC - Compliance | April 2012
exam experience posted by a VP‚ Lending/Credit/Loan Admin from member with under $250m in assets
none
FDIC - Compliance | August 2011
exam experience posted by a VP‚ Risk Management from member with between $250m - $500m in assets
The most unexpected aspect of the exam was the focus on the Dodd Frank Act even though most of it hadn't been formally enacted.

SEE ALL 10 EXAM WATCHES >>
RELATED VENDOR REVIEWS:
Safe Deposit Box Services
AMERICAN DEPOSIT SERVICES
On-site Class
Wolters Kluwer Financial Services
ABA Frontline Compliance Training
AMERICAN BANKERS ASSN
Training
BankersEdge
Internal Auditing Services
Compliance Services, Inc.

SEE ALL 12 Vendor Reviews >>
 
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