[Rich]

I am seriously confused regarding CE for LO’s. We are a Commercial Bank regulated by the FDIC and the Tennessee Department of Financial Institutions. As I understand it, as a Commercial Bank we are exempt from CE requirements under the SAFE Act. Under Dodd-Frank, what continuing education is required, and are there specifics for that education, for example XX hours of Ethics, XX hours of Compliance, etc?? HELP!!

[rcooper]

Rich,
You are correct, as a financial institution regulated by the FDIC (federally regulated) you shouldn’t have to be concerned with continuing education requirements under the SAFE Act, specifically 12 CFR 1007, for your lenders.

However, there is a general requirement in Regulation Z, 12 CFR 1026.36(f)(3)(iii) which states a loan originator organization must for each of its individual loan originator employees, who aren’t licensed under state (non-federally regulated) SAFE Act laws (12 CFR 1008), provide periodic training covering Federal and State law requirements that apply to the individual loan originator’s loan origination activities.

Since your FI is Federally regulated and there are no continuing education requirements for your LOs Reg Z requires that you provide them with periodic training on state and Federal law that apply to their loan origination duties. There are no specific content or timing requirements, but we like to use the SAFE Act state-licensing requirements as a guide.

The SAFE Act requires that state-licensed MLOs complete 8 hours of NMLS approved
continuing education which include the following (there are separate pre-licensing training requirements):
3 hours of Federal law and regulations;
2 hours of ethics that shall include instruction on fraud, consumer protection, and fair lending issues;
2 hours of training related to lending standards for the nontraditional mortgage product market; and
1 hour of undefined instruction on mortgage origination.

Jack covered Reg Z LO education on April 3 and 4, 2014. You also see reference to the amount of hours on our weekly agendas. The goal hours are in reference to the SAFE Act state-licensing education requirements (pre-licensing/continuing education).

[Author]

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