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| Iowa Mortgage Association - Prime Times Feb 16, 2010 In this issue: President's Message Free Webinar for IMA Members: Social Networking - Facebook and Twitter and Blogging Oh My! 2010 IMA Spring Conference: On Board for Success IMA Presidents Club & Winner's Circle Loan Production Awards Pending Home Sales Stabilize, Remain Above Year-Ago Levels MBA develops summary of President Obama's FY 2011 Budget Request USDA Rural Development Update HUD Revises Settlement Cost Booklet (Again) RESPA Revisited Mortgage Loan Originator Registry on the Horizon President's Message President's Message  2009-10 IMA President Kathy Klahn I hope you are all gearing up to attend the IMA Spring Conference on April 8, 2010, at the Marriott in Coralville. There are fantastic speakers lined up as well as breakout sessions on mortgage industry hot topics. Breakouts will include sessions on an update from the Division of Banking, updates from the VA and FHA, and one on our favorite topic, RESPA. The Annual Convention/Spring Conference Committee does a terrific job on designing the conferences to meet our current needs. If there are any future topics you would like to be considered for future IMA conferences or seminars, please e-mail Darcy Burnett and she will be happy to pass the word to the committee chair.One additional reason to attend is the knowledge you gain from fellow Iowa Mortgage Association members. The conference is a great networking opportunity. Over the years I have listened and learned from the best. Often we do not get outside our business's four walls enough to hear what is going on in other parts of Iowa. With all the changes in the industry, the knowledge you can gain from your peers with years' of lending experience is invaluable. The camaraderie within IMA is the best of the best. I again hope everyone is surviving RESPA in its newest form. There again, your membership in IMA gives you the opportunity to reach out to fellow members to find out how mortgage lenders are addressing new regulatory requirements in their organizations. We hope that 2010 brings good things to the mortgage industry. There are a lot of credit-worthy borrowers out there that we can help to overcome their fear of buying a home. If we can be of any help to you, please do not hesitate to ask. Contact me at Kathy.Klahn@clintonnational.net.Sincerely, Kathy Klahn Free Webinar for IMA Members: Social Networking - Facebook and Twitter and Blogging Oh My! Free Webinar for IMA Members: Social Networking - Facebook and Twitter and Blogging Oh My!
Topic: Iowa Mortgage Association Once you are approved by the host, you will receive a confirmation email with instructions for joining the session. For assistance you can contact Steve Richman at: steve.richman@genworth.com or (919) 870-2519.2010 IMA Spring Conference: On Board for Success 2010 IMA Spring Conference: On Board for Success
The Iowa Mortgage Association is dedicated to helping mortgage professionals. IMA has discovered that the key to success is working together. By providing opportunities for education, networking and industry awareness we raise the level of everyone in the industry. With the current public perception of the mortgage industry and stresses in our industry it is vital that we stand as one, working together for the future of the industry. By working together we will have a successful future. IMA is proud to present the 2010 Spring Conference: "On Board for Success." IMA has designed a full-day of educational opportunities. With sessions on reaching your potential, industry updates and an inspirational message, the Spring Conference will provide you with what you need to reach the summit as a mortgage professional! With sessions on being an effective originator, industry updates and an inspirational message, the Spring Conference will provide you with what you need to thrive as a mortgage professional! Take this opportunity to network with your peers from around the state, sharing ideas and solutions. As always the Spring Conference will also feature an exhibit hall with the latest products and services for the mortgage industry. Your peers, industry vendors, educational speakers and informative sessions will help you be successful in the mortgage industry. We look forward to seeing you at the conference and know you will discover ideas that will foster professionalism and success in your business! Registration is available on the IMA website at IMA Presidents Club & Winner's Circle Loan Production Awards IMA Presidents Club & Winner's Circle Loan Production Awards
The Iowa Mortgage Association is pleased to announce the Winner's Circle and President's Club awards. An ongoing recognition program, the club will consist of mortgage originators who meet certain criteria set from year to year. The originator must submit their entry form and be able to produce verification of the volume in written form to the selection committee. The members of the 2010 Winner's Circle and President's Club will be honored at the IMA Spring Conference on April 8. Criteria for the Iowa Mortgage Association's Winner's Circle & President's Club are listed below:
Pending Home Sales Stabilize, Remain Above Year-Ago Levels Pending Home Sales Stabilize, Remain Above Year-Ago Levels Pending home sales have leveled from a market swing driven by response to the home buyer tax credit, according to a report released by the National Association of Realtors® (NAR) on Feb. 2. The Pending Home Sales Index,* a forward-looking indicator based on contracts signed in December, increased 1.0 percent to 96.6 from 95.6 in November, and remains 10.9 percent above December 2008 when it was 87.1. In November, the monthly index had fallen by 16.4 percent from surging activity in preceding months. Lawrence Yun, NAR chief economist, said it’s important to recognize how the tax credit is skewing market data. “There are easily understood swings in contract activity as buyers respond to a tax credit that was expiring and was then extended and expanded,” he said. “These swings are masking the underlying trend, which is a broad improvement over year-ago levels. December activity was the fifth highest monthly tally in two years.” Buyers who have a contract in place to purchase a primary residence by April 30, 2010, have until June 30, 2010, to finalize the transaction to qualify for a tax credit of up to $8,000 for first-time buyers and $6,500 for repeat buyers. Yun projects the extended and expanded tax credit will encourage 2.4 million households to take the credit in 2010. “While new-home sales will remain low due to a lack of construction, existing-home sales are projected to rise to around 5.6 million in 2010,” Yun said. Last year there were 5.16 million existing-home sales. He added that one of the greatest benefits of rising sales will be firming home prices. “For several months now we’ve been seeing stabilization in all of the home price measures as inventory is pulled down,” Yun said. “As a result, the housing wealth for many middle class families has begun to stabilize.” * The Pending Home Sales Index is a leading indicator for the housing sector, based on pending sales of existing homes. A sale is listed as pending when the contract has been signed but the transaction has not closed, though the sale usually is finalized within one or two months of signing. The index is based on a large national sample, typically representing about 20 percent of transactions for existing-home sales. In developing the model for the index, it was demonstrated that the level of monthly sales-contract activity from 2001 through 2004 parallels the level of closed existing-home sales in the following two months. There is a closer relationship between annual index changes (from the same month a year earlier) and year-ago changes in sales performance than with month-to-month comparisons. An index of 100 is equal to the average level of contract activity during 2001, which was the first year to be examined as well as the first of five consecutive record years for existing-home sales. MBA develops summary of President Obama's FY 2011 Budget Request MBA develops summary of President Obama's FY 2011 Budget RequestTo keep members informed about the federal government's activities pertaining to mortgage credit, the Mortgage Bankers Association (MBA) developed a summary of the key provisions of President Obama's budget request for fiscal year 2011, which was submitted to Congress on Feb. 1. Click here to read the MBA's Administration 2011 Budget Request Housing Highlights. The proposed budget, which covers October 1, 2010 through September 30, 2011 (FY 2011), is the President's request for how the government should be run for that period. Congress will use the proposal as a basis for much of its debate this year as it legislates financial services regulatory reform, considers the long-term viability of FHA and other initiatives. The budget does not, however, propose a plan for Fannie Mae and Freddie Mac to exit government conservatorship. MBA SVP of Government Affairs Steve O'Connor said MBA will continue to focus the administration and Congress toward bolstering support for the housing finance system as well as MBA's other member priorities in the fiscal year ahead. USDA Rural Development Update USDA Rural Development Update: Two-Tier Income Structure Allows More Families to Become Eligible for Guaranteed Loan Program
Income limits vary by household size, where the house is located and which USDA Rural Development housing program is being used. For example, a family of four living in a rural area with an adjusted household income of up to $73,600 may qualify for the agency's guaranteed home loan program. Adjusted household income is calculated by deducting qualifying expenses for minor children, including childcare, from a household's total income. Eligible homes must be located in a rural community of 20,000 persons or less. Applicant's eligibility requirements include good credit history, adequate and dependable income for repayment ability of the loan. USDA Rural Development also provides guaranteed loans for business opportunities, as well as assisting communities in purchasing or building essential community facilities and services. For more information about any of USDA Rural Development's guaranteed loan programs, please call (515) 284-4666 or visit www.rurdev.usda.gov/ia.HUD Revises Settlement Cost Booklet (Again) HUD Revises Settlement Cost BookletHUD has updated its Settlement Cost Booklet (“Shopping For Your Home Loan”). HUD initially posted the revised booklet to its website in late December. On Jan. 6, 2010 HUD published a second revision that included “corrections of minor detail.” The booklet, as revised in January 2010, can be found in PDF and Word document format on HUD’s website at http://www.hud.gov/offices/hsg/ramh/res/settlement-cost-booklet01062010.cfm. HUD officials have verbally indicated to the Iowa Bankers Association that lenders who ordered and received booklets prior to the Jan. 6, 2010 minor corrections can continue to use the booklets. Upon exhausting the supply, the booklets should be replaced with the final revisions as provided in the Jan. 6 release. Lenders should keep in mind federal regulations prohibit changes to HUD’s new settlement cost booklet pursuant to HUD regulations found at 24 CFR 3500.6(c)&(d), “[no changes to, deletions from, or additions to the special information booklet currently prescribed by the Secretary shall be made...” RESPA Revisited RESPA RevisitedBy Ronette Schlatter, CRCM Iowa Bankers Association Nearly 90 days into 2010 and the RESPA questions keep mounting as lenders try to apply the revised Good Faith Estimate (GFE) and HUD disclosures rules. On January 28th, HUD released a series of new frequently asked questions (FAQs) to provide further clarification. This article will address frequently asked questions posed on the IBA Compliance Hotline that are not specifically addressed in HUD’s FAQs. As always, the responses provided in this article are based on the current available guidance provided by HUD...which may change with HUD’s next FAQs release! Important Date Issues Q. If the interest rate is locked at the time the GFE is issued, how should we complete Lines 1, 3, and 4 in the “Important Dates” section on the GFE? A. Per HUD’s FAQs, when the interest rate is locked before the GFE is issued, the information in Line 1 in the “Important Dates” section on the GFE must be completed by disclosing the date that the interest rate lock will expire, Line 3 must be completed to state the number of days the interest rate lock period is good through, and Line 4 must be completed with “N/A.” Q. If the interest rate is NOT locked at the time the initial GFE is issued, how should lines 1, 3 and 4 be completed? A. If the lender does not offer a rate lock option, then Lines 1, 3 and 4 should state “Not Available” or “N/A.” If the lender does lock interest rates, but has yet to do so at the time the GFE is issued, the lender must state the date and time (if applicable) through which the interest rate noted on the GFE will be available, which could very well be the date and time the GFE was issued and no longer. The lender must then disclose on Line 3 how many calendar days within which the applicant must go to settlement once the interest rate is locked. Obviously, the number of days cannot be determined until the rate is actually locked. In this case, Line 3 in the “Important Dates” section should be completed with rate lock period typically used by the lender and should take into account factors affecting the settlement date such as rescission periods and delivery of the loan file to the investor. Once an interest rate is locked, a revised GFE will need to be issued to update Lines 1 and 3 to reflect the actual rate lock period and change Line 4 to “N/A”. Fee Placement Issues Q. Do we have to include the cost of Owners Title Insurance in Block 5 on the GFE, even if we do not require it as a condition of the loan? A. Yes. The GFE instructions and HUD FAQs both indicate lenders must provide an estimate of the charge for an owner‘s title insurance policy in Block 5 on the GFE for all purchase transactions. For non-purchase transactions, the lender may enter “N/A” or “Not Applicable” in Block 5. The IBA was able to verbally confirm with HUD legal counsel in early January that owner’s title insurance is to be disclosed on the GFE for all purchase transactions, EVEN IF IT IS NOT REQUIRED BY THE LENDER AS CONDITION OF THE LOAN. The State of Iowa does not authorize the sale of title insurance and in its place, the Iowa Finance Authority (IFA) will issue a Title Guaranty certificate. As such, lenders are advised to include the cost of an owner’s Title Guaranty certificate on purchase money GFEs in order to comply with the GFE’s general instructions. If the lender is purchasing lender’s Title Guaranty through IFA, there is no additional charge for an owner’s policy. Thus, $0 should be entered on the GFE. If the lender is NOT requiring the purchase of a lender’s policy, the cost for an owner’s-only policy is $110 for up to $500,000. An owner’s policy in excess of $500,000 is $110 plus $1 per $1,000 over $500,000 (round up to nearest $1,000.) Q. Where should the lender disclose an “escrow waiver fee”? A. According to HUD’s FAQs, an escrow waiver fee is a type of loan level price adjustment and should be included as part of the calculation of Block 2 on the GFE. Alternatively, if the escrow waiver is known at the time of application, the charge for the escrow waiver can be included in “Our origination charge” disclosed in Block 1. If a borrower asks to waive the escrow account after the interest rate has been locked, the lender may issue a revised GFE based upon the borrower’s requested change. Charges associated with the escrow account waiver should be disclosed by adjusting Block 2 on the revised GFE. It is important to note, however, an escrow waiver cannot be considered a borrower-requested change and the GFE cannot be revised to reflect an escrow account waiver charge if the initial GFE stated that there was no escrow account on the loan. Q. Where should we disclose items such as a home inspection or home warranty that the borrower may purchase but is not required by the lender as a condition of the loan? A. Since these items are not lender-required settlement services, they should not be included on the GFE. The 1300 series of the HUD-1 Settlement Statement is used to record the charges for settlement services that are disclosed in Block 6 of the GFE, “Services you can shop for,” as well as charges that are not disclosed on the GFE. Examples of some of these services may include charges for surveys, pest inspections, radon inspections and homeowner‘s warranty that the borrower voluntarily elects to purchase. Q. If the customer voluntarily purchases credit life and disability insurance for their loan, must the cost be disclosed on the GFE and if so, where? Where is the premium disclosed on the HUD? A. If the credit insurance is not required by the lender as a condition of the loan, it should not be included on the GFE. If the customer voluntarily purchases the insurance product and the premium is paid at closing (either in cash or from the loan proceeds), the premium amount should be disclosed on a blank line in the 900 series. The HUD instructions indicate “Lines 904 and additional sequentially numbered lines are used to list additional items required by the Lender (except for reserves collected by the Lender and recorded in the 1000-series), including premiums for flood or other insurance. These lines are also used to list amounts paid at settlement for insurance not required by the Lender.” Taxes & Insurance Q. Where does the lender disclose annual taxes or tax installments due and payable on the GFE and HUD settlement statement? A. Block 9 on the GFE provides for the disclosure of the estimated deposit of taxes and insurance into the escrow account. Amounts due and payable at closing for taxes are not disclosed on the GFE as they do not fall under HUD’s definition of a “settlement cost.” The lender may want to consider providing a cover letter with the GFE advising the borrower that in addition to amounts detailed on the GFE, the borrower will also be required to pay taxes due at the time of closing. The instructions for the HUD settlement statement do not specifically address disbursements for taxes due, nor do HUD’s FAQs. The instructions do, however, indicate the 900 series on the HUD should be used to disclose items required by the lender to be paid in advance. Therefore, it would seem appropriate a blank line in this series (such as line 904) could be used to show the tax payment due. In a refinance or home equity loan, the tax payment could also be disclosed as a “disbursement to others” in the 1500 series. Q. If the annual tax amount is no longer included on the GFE, do we still have to disclose the annual homeowner’s insurance premium? A. Yes. If the payment of the homeowner’s insurance is a condition of the loan (NOTE: most mortgages do contain a clause requiring homeowner’s insurance), the annual policy premium must be estimated in Block 11 on the GFE. In the case of refinances or subordinate lien loans where the borrower can evidence an existing policy is in place, the actual annual premium amount can be detailed on the HUD statement as paid outside closing by the borrower (POC-borrower) on line 903. Fees Not Passed on to Borrower Q. Our bank considers the credit report as a “cost of doing business” and never passes the cost on to the borrower. Since we cover the fee, does it still need to be disclosed on the GFE? A. Yes. While the bank may consider the credit report a “cost of doing business,” RESPA includes a credit report in its definition of a “settlement service.” Lenders are required to disclose the cost of all “settlement services” performed in conjunction with a transaction on the GFE, regardless of who pays the cost. HUD’s Jan. 28, 2010 update to its FAQs added a Q&A on this very topic:
Therefore, even if the lender always covers the cost of the credit report, the credit report fee should be disclosed in Block 3, “Required services we select.” The lender can then disclose a credit in Block 2 to offset the credit report fee. The HUD instructions indicate any fee disclosed as a borrower cost on the GFE, must be disclosed in the borrower’s column on the HUD. The Jan. 28, 2010 updated FAQs appear to give the lender two options to disclose the fact the lender is covering the cost:
Q. Many times, we will refinance an existing loan on our books and instead of ordering a new appraisal and title search, the bank will rely on the existing appraisal, title work and reference an existing open-end mortgage as collateral. The only actual out-of-pocket expense on the refinance is a credit report fee and fee for a new flood determination. Must the bank include the appraisal fee, title search fee and mortgage recording fee on the GFE and then detail the fees on the HUD as a POC-borrower items, even if it the fees will not actually be incurred with this transaction? (Again, the consumer paid these fees with the previous transaction.) A. Unfortunately, none of HUD’s official FAQs guidance specifically addresses “reuse” of settlement services for subsequent loans; whether refinance of an existing loan or a new subordinate lien loan. However, IBA’s correspondence with HUD RESPA specialists indicates that a lender should only disclose settlement services conducted with the current transaction. The lender does NOT have to redisclose the cost of settlement services that are being reused and therefore, the cost is not actually being incurred with the transaction at hand. The lender is only required to disclose actual settlement costs being incurred with the consumer’s current application. However, keep in mind the lender must disclose all actual costs incurred with the current transaction regardless of who is paying for the cost. For example, using the example stated above, the lender is reusing the appraisal, title work, and an existing mortgage, thus these costs are not detailed on the GFE and HUD. However, the lender does order a new credit report and flood determination, so the lender must detail the cost of the credit report and flood determination on the GFE and HUD. (Refer to the previous question regarding lender-paid fees if the bank will cover the credit report and flood determination fees on behalf of the borrower.) Changing GFE Fees Q. At the time we lock in an interest rate for the customer, we must provide a revised HUD. Are we allowed to revise the Block 1 total (“Our origination charge”) as a result of the borrower-requested change (locking in a rate)? A. While the GFE instructions and regulation do not specifically address this, again HUD’s FAQs provide guidance and indicate that once an initial GFE is issued, there are only a few circumstances in which Block 1 fees can change and locking in a interest rate is not one of them. However, Block 1 can increase due to a changed circumstance if the change affects the loan amount and all or a portion of the origination charges were calculated as a percentage of the loan amount. Block 1 may also increase if the borrower either requests a different loan product or the borrower is no longer eligible for the loan product contained in the initial GFE, but is eligible for a different loan product. Such changes need to be carefully documented in the loan file. Once an initial GFE is issued, the amount in Block 2 can only be adjusted to show any additional charge or credit for the interest rate selected by the borrower at the time an interest rate is locked. Note: Ronette Scholatter, CRCM is Senior Compliance Coordinator for the Iowa Bankers Association. Mortgage Loan Originator Registry on the Horizon Mortgage Loan Originator Registry on the HorizonBy Ronette Schlatter, CRCM Iowa Bankers Association The Secure and Fair Enforcement for Mortgage Licensing Act of 2008 (SAFE Act) was drafted with goal of improving the accountability and tracking of residential mortgage loan originators (MLOs), enhancing consumer protection, reducing fraud and providing consumers with easily accessible information regarding the professional background of MLOs. The registration requirements of Section 1507 of the SAFE Act apply to federally-regulated financial banks, their subsidiaries and employees of such banks or subsidiaries who act as MLOs. MLOs who are NOT employees of federally-regulated banks are required to become licensed with the State in which they operate. Information related to licensing requirements can be obtained from the Iowa Division of Banking. When the SAFE Act was enacted by Congress on July 30, 2008, it is highly unlikely any of the bill's authors anticipated the massive undertaking a nationwide registry system would present. Proof positive of that is the Act's directive to the federal banking agencies to develop and maintain a system for registering MLOs of depository institutions and their subsidiaries within one year of the bill's enactment. It took nearly a year for the proposed rule to be issued! The proposed rule, issued in June 2009, discussed in detail the careful analysis of complex legal and system development issues that had to be addressed in order to adapt the Conference of State Bank Supervisors and American Association of Residential Mortgage Regulator's Web-based registry system to accept the massive number of registrations from MLOs employed by Agency-regulated institutions. The modified registry will be renamed the "Nationwide Mortgage Licensing System and Registry" (the Registry) once it is functional. In November 2009, the draft final rule implementing the SAFE Act was made public (see http://www.fdic.gov/news/board/2009nov12no8.pdf). The final rule is pending publication in the Federal Register until such time all the federal agencies involved in the rulemaking have completed their review and approval of the rule. That process is currently in progress. The final rule effective date will be announced once it is published in the Federal Register. Once the Registry is functional, employees of Agency-regulated institutions will have 180 days to complete the initial registration process.The draft final rule:
A key to complying with the registration rule is understanding who is and is not a "Mortgage Loan Originator" (MLO) in your institution. The final rule defines an MLO as "an individual who: (i) takes a residential mortgage loan application; and (ii) offers or negotiates terms of a residential mortgage loan for compensation or gain." The term does NOT include:
There is a "de minimis" exception provided in the final rule for small institutions - really small institutions. Employees of institutions who have never been registered as an MLO and during the last 12 months have originated five or fewer residential mortgage loans are not required to comply with the new Registry provisions. MLO Registry Requirements Each employee of a federally-regulated financial institution who meets the definition of an MLO must:
Initial Registration Regulated institutions must require all persons identified as MLOs to submit the following information to the Registry (or must submit the information on behalf of the employee): 1. Identifying information, including the employee's name and any other names used; home address and contact information; address of the employee's principal business location and business contact information; Social Security number; gender; and date and place of birth; 2. Financial services-related employment history for the 10 years prior to the date of registration or renewal, including the date the employee became an employee of the bank; 3. Convictions of any criminal offense involving dishonesty, breach of trust, or money laundering, or agreements to enter into a pretrial diversion or similar program in connection with the prosecution for such offense, against the employee or organizations controlled by the employee; 4. Civil judicial actions against the employee in connection with financial services related activities, dismissals with settlements, or judicial findings that the employee violated financial services-related statutes or regulations, except for actions dismissed without a settlement agreement; 5. Actions or orders by a State or Federal regulatory agency or foreign financial regulatory authority that:
7. Revocation or suspension of the employee's authorization to act as an attorney, accountant or State or Federal contractor; 8. Customer-initiated financial services-related arbitration or civil action against the employee that required action, including settlements, or which resulted in a judgment; and 9. Fingerprints of the employee, in digital form if practicable and any appropriate identifying information for submission to the Federal Bureau of Investigation and any governmental agency or entity authorized to receive such information in connection with a State and national criminal history background check; however, fingerprints provided to the Registry that are less than three years old may be used to satisfy this requirement. Maintaining Registration Once an MLO has met the registration requirements, the SAFE Act requires the MLO to renew his/her registration annually during the "annual renewal period." The "annual renewal period" is defined as Nov. 1 through Dec. 1 of each year. The annual registration renewal requirement does not apply to a registered MLO who has completed the initial registration process less than six months prior to the end of the annual renewal period. For example, if an MLO's initial registration occurred after July 1, 2010, the MLO would not have to renew their registration until the Nov. 1 through Dec. 31, 2011 annual renewal period. In addition, the MLO must also update his/her registration if any of the following events occur:
Each employee registering as an MLO or renewing his/her registration must:
MLO Unique Identifier When a person completes the registration process, the Registry will assign a "unique identifier" which is a number that will permanently identify the registered MLO. This unique identifier electronically tracks the MLO and provides a uniform method for public access to employment history and public adjudicated disciplinary and enforcement actions against the MLO. A registered MLO must provide his or her unique identifier to a consumer:
The final rule requires institutions that employ MLOs to adopt and follow written policies and procedures designed to ensure compliance with the SAFE Act. As with all policies and procedures, the requirements should be appropriate to the nature, size, complexity and scope of the mortgage lending activities of the institution. Thus, the policies and procedures for a small institution with a handful of MLOs will be much simpler than that of a large, multi-branch institution. The final rule requires, at a minimum, the policies and procedures must:
The draft final rule indicated the Agencies will publicly announce the date on which the Registry will begin accepting registrations, which will mark the beginning of a 180-day period during which employees of Agency-regulated institutions must complete the initial registration process. The IBA will alert members via "The Disclosure" and "Communiques" when the announcement is made and registration deadline is set. When fully operational, MLOs and their Agency-regulated institution employers are expected to have access to the Registry, seven days a week, to establish and maintain their registrations. Just because the final rule has yet to be published in the Federal Register and the Registry is not functional does not mean institutions can delay in preparing for the registering process. Institutions should begin NOW to develop the written policies and procedures needed to implement the SAFE Act registration provisions, test for compliance and begin the employee education process. Institutions who wait and don't begin the planning process until the Registry is functional and the 180-day registration period has begun will likely find themselves scrambling to get their MLOs registered before the deadline. Editor's Note: This article was originally published in the Feb. 2010 issue of The Disclosure, the Iowa Bankers Association's monthly compliance magazine. To remove yourself from this mailing list, click here. |
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