Wednesday, March 24, 2010

FYI: FFIEC Issues FAQs on SAFE Act Registration for Depository Institutions

The Federal Financial Institutions Examination Council published a question and answer document regarding licensing obligations of depository institutions under  the Secure and Fair Enforcement for Mortgage Licensing Act.  See:
 As you may recall, the SAFE Act requires individual mortgage loan originators to register with the Nationwide Mortgage Licensing System and Registry, a database established by the Conference of State Bank Supervisors and the American Association of Residential Mortgage Regulators to support the licensing of mortgage loan originators by the states.  
The FDIC recently approved a draft final rule (attached) to put the federal registration requirement into effect, which will require registration by individual residential mortgage loan originators employed by agency-related institutions. These originators will obtain a unique identifier that will stay with them regardless of employment.  The draft rule would provide financial institutions with 180 days to complete initial registrations once the system is operational.
The FDIC's draft final rule is currently under review by the Office of Management and Budget pursuant to Executive Order 12866.
Let me know if you have any questions.  Thanks.


Ralph T. Wutscher

Kahrl Wutscher LLP

The Loop Center Building

105 W. Madison Street, Suite 2100
Chicago, Illinois  60602
Direct:  (312) 551-9320 

Fax:  (866) 581-9302
Mobile:  (312) 493-0874


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