Responses to 8.23.13 CMG Questions

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    from (privately):
    Would it be compliant to combine the SAFE act policy and the LO policy into one policy?
    RESPONSE: There is nothing that prohibits you from combining the topics. It makes a lot sense to do it that way. Thanks for the suggestion.

    from Joan Britt to Everyone:
    Did I understand correctly that the “security” instrument that must contain the NMLSR ID numbers of the bank and the employee are: security documents from our software as well as the DOT, UCCs etc. ???
    RESPONSE: Yes, your understanding is correct.

    from (privately):
    Need clarification…do we need to follow these procedures for all of our employees that are MLOs now? Do we need to get a copy of the criminal background check on all these?
    RESPONSE: You are required to collect and evaluate information for each of your individual loan originator employees who is not required to be licensed and is not licensed as a loan originator pursuant to § 1008.103 of this chapter or State SAFE Act implementing law before the individual acts as a loan originator in a consumer credit transaction secured by a dwelling. The information must be obtained for:
    • Any individual whom the loan originator organization hired on or after January 10, 2014;
    • Any individual hired before January 10, 2014 but for whom there were no applicable statutory or regulatory background standards in effect at the time of hire or before January 10, 2014, used to screen the individual, including loan originators who were not MLOs
    • Any individual regardless of when hired who, based on reliable information known to the loan originator organization, likely does not meet the standards under § 1026.36(f)(3)(ii).

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