Community Bankers Association of Illinois

Reminder: Banks must adopt S.A.F.E. Act policy by October 1, 2010

September 9, 2010 --- Pursuant to federal regulations adopted under the Secure and Fair Mortgage Licensing Act of 2008 (“S.A.F.E. Act”), bank-employed mortgage loan originators will be required to register with the Nationwide Mortgage Licensing System & Registry (“the Registry”) developed by the Conference of State Bank Supervisors and the American Association of Residential Mortgage Regulators. In a Joint Statement published in July, the federal regulatory agencies indicated that the Registry was not yet prepared to accept registrations from bank-employed mortgage lenders and that the registrations might not commence until January of 2011 (bank-employed mortgage lenders will have 180 days following the federal regulator’s announcement of the start of registrations to meet their registration requirement.) However, even though individual registrations are not yet occurring, the Office of the Comptroller of the Currency and the FDIC have advised that banks must adopt written policies to ensure compliance with the S.A.F.E. Act regulations, and those policies must be adopted by a deadline of October 1, 2010. To view the federal S.A.F.E. Act regulations, click here, and pay particular attention to Section 365.104 (“Policies and procedures”) for details regarding the items that must be addressed in the bank’s written policy. If you have any questions, please feel free to contact CBAI General Counsel Jerry Cavanaugh by e-mail ( or telephone (1/800-736-2224).

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