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Develop a Compliance Management Program to Properly Identify and Oversee Staff for SAFE Act and Reg Z Rules!
Various regulatory requirements apply to employees at your organization, depending on if they are a Mortgage Loan Originator (MLO); a Loan Originator (LO); both; or neither. Do you know what each employee is? Do they?
Making a proper determination of what each employee actually does in their job is foundational to building a solid compliance management program. In addition to SAFE Act requirements, Reg Z contains complex rules for employees involved in home lending including: qualification requirements, compensation restrictions, disallowed payments, and steering prohibitions.
The SAFE Act has been around for a while now, and with time, full understanding and insights dwindle. Staff members change and processes evolve. Why are you doing what you do? Take a new look at the requirements to make sure “what you’ve always done” is still appropriate and accurate.
Reg Z’s requirements at 1026.36 have always been complex, and the passage of time has not made them any clearer. Examiners continue to look at this area of compliance with a fine-toothed comb, and your policy and procedures need to consider new lending programs, referral promotions, evolving employment roles, and broker relationships. Don’t be caught off guard.
Don’t leave this matter solely in the hand of Human Resources, even if it is rooted in employment issues. Does your HR department know the details of the SAFE Act and Reg Z? Surely not. That leaves you, the compliance professional, to develop and implement a rock-solid plan to comply.
This webinar will review SAFE Act and Reg Z requirements for MLOs and LOs, define and dissect key terms such as “Mortgage Loan Originator”, “Loan Originator” and “Compensation”, explore the impact of referral programs, and detail the requirements every LO must meet. In addition to the webinar slides and manual, participants will receive a sample program to customize for their own institution, including a policy, employee survey, and sample training materials for in-house employee training.
Upon completion of this two-hour program participants will understand:
- Compare and contrast MLOs and LOs
- Requirements MLOs must follow;
- Requirements LOs must follow, including all 1026.36 provisions
- How overly helpful employees can find themselves meeting the LO definition;
- The Gotcha! game of referral and/or cross-selling programs;
- Scenarios to illustrate real world examples;
- Going beyond job titles;
- Who owns MLO / LO oversight;
- How to write (or update) an appropriate MLO / LO Program;
- How to train all your employees, not just loan staff;
- How to administer and track an employee survey;
- Auditing the program
- Sample Policy;
- Sample Employee Survey;
- Sample Training Materials.
Who Should Attend:
Compliance staff, HR officers, lending managers and auditors.
Sample SAFE Act Policy
MLO v. LO Comparison Table
Sample Loan Origination Policy
Questions and Answers