Compliance Q&A: OFAC, FCRA, and the SAFE Act

When must mortgage loan originators be fingerprinted?

August 24, 2011
KEYWORDS credit , regulation
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Q Does the SAFE Act require mortgage loan originators (MLOs) to be fingerprinted every three years?

A The regulation requires MLOs to submit fingerprints to the Nationwide Mortgage Licensing System & Registry (NMLS) for a criminal background check. But MLOs don’t have to be fingerprinted every three years.

Fingerprints are only required at initial registration, and when MLOs change their place of employment and current fingerprints on file are more than three years old.

Refer to NCUA’s regulations (Sec. 761.103(a)(4)(i)(B): Employees previously registered or licensed through the registry).

The re-registration requirements apply when employees transfer from one financial institution to another and both institutions are covered under the SAFE Act regulations.

And they also apply when individuals are state-licensed under the SAFE Act prior to transferring to financial institutions covered by these rules.

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