The annual MLO (Mortgage Lending Originators) registration renewal period is coming!
As you will all remember, the Secure and Fair Enforcement for Mortgage Licensing Act (SAFE Act) created the NMLS Federal Registry where all mortgage lending originators (MLOs) must be registered before working. The annual renewal period begins on November 1, 2013. Every MLO at your institution must have his information updated and renewed (and there are fees to be paid too).
The person designated to help your MLOs renew their registrations is called the NMLS System Administrator. Your institution should have designated (at least by job title) someone to hold this position. Basically, a System Administrator is the person who has the authority to access and enter data into the Registry electronically. This person (or persons) is responsible for registering new personal information on MLOs, keeping the information current, and reporting any changes in employment or discipline actions.
There are a few minimal requirements in order to be a System Administrator:
1. Must be currently employed by the institution
2. Must verify their identity
3. CANNOT BE AN MLO (Unless the “de minimis” exception – Less than 10 people employed at the institution applies)
Consequently, the choice of NMLS System Administrator can be very wild open. While much of the actual work is clerical, this individual must deal with personal and confidential information. Also, this person cannot typically be involved in mortgage lending. In my SAFE act reviews and audits, I have seen many different positions selected.
Here are a few common choices:
1. Human Resource Officer:
This job position is an excellent choice to be a system administrator. They already have access to personal information regarding the employees, they are aware when someone is either employed or let go, and they are almost never MLO’s. The human resource officer can be a very effective system administrator because they are directly aware of changes as they happen.
2. Compliance Officers:
Remember they must not be a MLO. But if your Compliance officer is not an MLO, then they can be a good choice because Compliance Officers typically know the Federal Regulations and will be familiar with the aspects of the SAFE Act.
3. Executive Assistants:
I have seen several Executive Assistants serve as NMLS Administrators. Some regulators feel this is not positions commiserate with the importance; however, I have seen Executive Assistants fulfill the requirements well.
As the annual renewal date approaches, it is important that your institution has an NMLS administrator and that all your MLOs renew their registrations.
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