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NH/VT 2011 JOINT COMPLIANCE CONFERENCE

NH/VT 2011 JOINT COMPLIANCE CONFERENCE. Safe Act Update for Depositories. Ben Niles, Risk Manager bniles@merrimackmortgage.com 603-606-3272 603-305-0590 (C). SAFE Act. The content of this presentation is for information purposes only. I am not an attorney and am not providing legal advice.

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NH/VT 2011 JOINT COMPLIANCE CONFERENCE

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  1. NH/VT 2011 JOINT COMPLIANCE CONFERENCE Safe Act Update for Depositories Ben Niles, Risk Manager bniles@merrimackmortgage.com 603-606-3272 603-305-0590 (C)

  2. SAFE Act • The content of this presentation is for information purposes only. I am not an attorney and am not providing legal advice. • It is recommended that you also seek guidance from your legal counsel for compliance issues and questions.

  3. SAFE ACT- Depositories • Requires OCC, FRB, FDIC, OTS, FCA & NCUA to develop a system for “Registering MLO’s” • Dodd-Frank passed 7/21/10: CFPB • Depository Regulations issued 7/28/10 implementing SAFE ACT • NMLS modified to accept “registrations”

  4. Depository Regulations Published • Regs published in Fed Register 7/28/10 • 12 CFR Part 34 • 208, 211, 365, 563,610, 741, & 761 • MLO Registration Required via NMLS • Deadline of 7/29/11

  5. MLO Defined • Loan Originator: • takes a residential mortgage loan application, or • assists a consumer in obtaining or applying to obtain a residential mortgage loan, or • offers or negotiates terms for a residential mortgage loan, or • advises on loan terms, preparing loan packages, or collecting consumer information, • and is paid direct or indirect compensation or gain

  6. Who is Not A Mortgage Loan Officer? • Management/Administrative Exemption • Loan Processor • Underwriter • Branch Support Staff? • Fulfillment Dept Staff (think Mortgagebot)? • Servicing Staff- Loan Mods? • Exemption: max 5 loans in previous 12 months

  7. Is a Branch Manager an LO? • Producing Branch Manager VS • Non-Producing Branch Manager

  8. NMLS Registration • FBI Background Check- Fingerprints • criminal background check, i.e. - civil & felony convictions • Personal History & Experience • 10 Yr employment history- financial services • Financial Responsibility Review- credit report

  9. License Issuance- Minimum Standards • LO license never revoked • Never convicted, pled guilty, or nolo contendere to a felony • Demonstrated financial responsibility, character & fitness…

  10. What is not Required • 20 hours of pre-licensing education • National & state exams • 8 hours of continuing education annually

  11. NMLS Registration “How To” • Google “NMLS Resource Center” • Click on “Getting Started- Company or Institution • Click on “Federal Registration” • 12 Step Process • Numerous links to Guides, FAQ’s, Forms, Workflows, & Charts • HR may do most of the work • MLO completes MU4R- Personal Information • MLO submits fingerprints

  12. MLO/ NMLO Registration Questions?? Ben Niles, Risk Manager Merrimack Mortgage Company bniles@merrimackmortgage.com 603-606-3272 603-305-0590 (C)

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