Federal Registry for National Licensing Now in Effect
by Lindsay Sayre Kift, Esq.
Associate Counsel and Client Services Director
The Race Is On: NMLS Federal Registry Opens
On Monday, January 31, 2011, the Conference of State Bank Supervisors (“CSBS”) announced the opening of the Nationwide Mortgage Licensing System (“NMLS”) Federal Registry. NMLS is now accepting registration filings from institutions and mortgage loan originator (“MLO”) personnel covered by the Federal Agencies’ final rule implementing the S.A.F.E. Act.
According to the final rule, banks, savings associations, credit unions, or Farm Credit System (FCS) institutions as well as certain subsidiaries regulated by a Federal banking agency or the FCA (collectively, Agency-regulated institutions) who act as a residential mortgage loan originator are required to register with the NMLS and Registry (Registry). Agency-regulated institutions must also obtain a unique identifier from the Registry and maintain this registration. The initial registration period will run from January 31, 2011 to July 29, 2011.
To help your organization maintain its important compliance and employee education goals, please contact me at 617-489-2008 or by email lindsay@bankersadvisory.com
Compliance Training
and are followed by Live Q&A
Every question will be answered during the call or by follow up e-mail
Loan Officer Compensation – February 16th
Definitions, Prohibitions, Safe Harbor, and Examples and Explanations
• Who is defined as a Loan Originator and who is not?
• What are the 3 key prohibitions on Loan Originators?
• Examples of permissible forms of compensation
• Definitions of loan terms & conditions explained
• Explanation of the Safe Harbor and exceptions to the prohibitions
• Detailed illustrations of permissible & impermissible scenarios
• Clear & understandable mathematical examples on real life deals
• Commission structures & permissible incentives
• Management compensation
• Broker / creditor fee arrangements
Mortgage Disclosure Improvement Act (MDIA) – February 23rd
January 30, 2011 Compliance Requirements
• Changes since enactment of MDIA
• Review of definition of Business Day
• Collection of Fees
• Transaction-specific disclosure examples
• Examples of new requirement of how payments will change
• Form & format of disclosure
• Early disclosure timing requirement
• Re-disclosure timing requirement
Real Estate Settlement Procedures Act (RESPA) – March 2nd
Refresher Course on last year’s RESPA major revisions
• Good Faith Estimate timing & disclosure of fees
• Revision of the GFE & changed circumstances
• Origination & interest-rate related charges
• Illustration of pricing scenarios
• Third party services
• HUD1 tolerance thresholds
• Examples of various scenarios of GFE
• Examples of various scenarios of HUD1
FACTA Red Flags Identity Theft – March 9th
December 30th Compliance Requirements for Brokers & Lenders
• Definition of creditors & covered accounts
• Required steps Address Discrepancies under FACTA
• Examples of red flags by Federal Trade Commission
• Examples of detection, response & mitigation
• Role of processors, underwriters & closers
• Program implementation & training
• Data center security & vendor management
Marissa Aquila Blundell, Esq., is Vice President and Senior Counsel at Banker Advisory. Marissa authors the rule summaries for all 50 States published by All Regs. She is a graduate of Skidmore College, New England School of Law and is admitted to the Massachusetts Bar.
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