WASHINGTON (9/14/10)--The Credit Union National Association (CUNA), in response to inquiries, has written a sample policy that credit unions may find useful to review in developing their own Safe and Fair Enforcement for Mortgage Licensing Act (SAFE) policy that must be adopted by Oct. 1. “Credit unions are concerned about how to devise a policy to comply with the SAFE regulations when they are uncertain about all the actual registration requirements,” said Valerie Moss, CUNA’s director of compliance information. “CUNA has put together a sample drawn from the regulatory requirements and definitions. As the National Credit Union Administration admitted in a recent Letter to Credit Unions on SAFE (No. 10-CU-13), a credit union is going to have to revisit whatever SAFE policy it adopts and develop its actual procedures once the registration procedures are announced by the Conference of State Bank Supervisors (CSBS), which is in charge of developing the national registry,” she added. “Besides requests for a sample policy, we’ve received a number of questions on who is actually required to do the background check,” Moss noted. “The CSBS told us last week that it will be a ‘fingerprint-based criminal background check.’ The employee required to register will be directed to local offices where fingerprints will be taken in order to maintain a secured process. The registry’s network, not the credit union, will conduct the background check based on the fingerprints.” CSBS told CUNA last week that 95% of the fingerprints taken in its current licensing system have been digital, which provides greater accuracy with a quick turnaround time. Credit unions should generally expect to receive the background report within 24 hours, unless there are problems with the quality of the fingerprints, which of course will delay the ability to get the individual employee registered. As reported yesterday, credit unions will be charged a fee, yet to be announced, for the background check. Use the resource links below.