WASHINGTON (1/13/11)--As credit unions and other mortgage loan originators (MLOs) await final notice from federal regulators that the SAFE Act national mortgage registry is open for registration, they may be pondering many variables, some of which are visited by this month’s Credit Union National Association Compliance Challenge. For instance, credit union compliance folks--always alert to find ways to comply with rules in the most cost- and time-efficient manner possible--may be wondering whether a little recycling may be in order. Can a credit union that already has obtained fingerprints and background checks on prospective employees simply upload this information into the Nationwide Mortgage Licensing System & Registry (NMLS), or do employees have to be re-fingerprinted and go through another background check? Compliance Challenge advises that there is no chance for recycling here: A credit union’s employees who are identified as MLOs will have to be fingerprinted again and go through another background check. The SAFE Act requires MLOs to submit fingerprints to the NMLS for the purpose of conducting a criminal background check. Fingerprints will be submitted to the FBI, which will return any information resulting from the background check to the credit union through the NMLS. So, the NMLS will manage the entire process, from fingerprint capture to the return of the criminal background check to the credit union through the new system once it’s up and running. Fingerprints will be taken at an NMLS-authorized fingerprint vendor. Information will be forthcoming, but to see how this process works on the state licensing side, see the resource link. Note that the initial period for federal registration of residential mortgage loan originators is expected to begin on or around Jan. 31, and end on or around July 29. The National Credit Union Administration and the federal banking regulators will publish an announcement on their respective websites confirming the start date of the registration period shortly before the period begins. Then credit unions and their MLOs will have 180 days from the date indicated in the notice to register on the new system. To see more on the SAFE Act and to take the CUNA Compliance Challenge, use the resource link below.