Regulation G (12CFR§1007.103(b)) requires that the NMLS registry should be updated within 30 days for significant changes, including name changes, employment termination, and reportable changes to legal or regulatory actions. CNB SAFE Act procedures also state that the Mortgage Loan Registration Administrator (MLRA) is responsible for updating the terminated MLO’s information in the NMLS Registry within 30 days of the date an MLO ceases to be an employee. The audit noted:
• 5 out of 7 terminated MLOs tested during the audit were not timely updated in the NMLS Registry.
Recommendation
Corporate Compliance should perform the SAFE Act reconciliation quarterly to confirm that colleagues who no longer have authority to act as a CNB MLO is timely
• 5 out of 7 terminated MLOs tested during the audit were not timely updated in the NMLS Registry.
Recommendation
Corporate Compliance should perform the SAFE Act reconciliation quarterly to confirm that colleagues who no longer have authority to act as a CNB MLO is timely