The SAFE Act requires an annual independent review to ensure compliance with SAFE Act regulatory requirements. We have developed testing procedures to help financial intuitions meet this independent review requirement with efficiency at a very low cost by performing these reviews remotely. Our report of findings and recommendations will be promptly provided to management at the conclusion of transaction testing. A brief summary of the procedures to be completed are below:
- Ensure adequate administration/oversight of program
- Review MU4R and MU1R filings for accuracy
- Review sample of mortgage loans originated and denied by each of your Bank’s MLOs to ensure adequate use of NMLS number
- Review policies and procedures based on CFPB’s exam procedures
- Ensure annual renewal process is timely
- Ensure any MU4R and MU1R information is updated timely when required
- Verify the bank makes the unique identifier(s) of its MLOs available to consumers in a manner & method practicable to the Bank