Under the Secure and Fair Enforcement for Mortgage Licensing Act (S.A.F.E. Act) and the final rules issued on July 28, 2010, residential mortgage loan originators employed by banks, savings associations, credit unions, Farm Credit System institutions, and certain subsidiaries of these financial institutions must register with the Nationwide Mortgage Licensing System and Registry (Registry), obtain a unique identifier from the Registry, and maintain this registration.

The initial period for federal registration of residential mortgage loan originators pursuant to the S.A.F.E. Act is expected to start on or around January 31, 2011, and end on or around July 29, 2011. The Office of the Comptroller of the Currency (OCC) will publish an announcement on its Web site confirming the start date of this registration period shortly before it begins, followed by a notice in the Federal Register.

Employees of national banks and their subsidiaries will have 180 days from the start date to complete their initial registrations. After this 180-day period, anticipated to expire on or about July 29, 2011, any employee subject to the registration requirements will be prohibited from originating residential mortgage loans without first meeting these requirements.

National banks are encouraged to visit the Registry Web site before the expected start date. The Web site has information about what institutions can do before the registration period begins to facilitate the process. National banks also may find more information about federal registration requirements by visiting the OCC’s Web site. They may e-mail questions about federal registration to SafeActSystem@occ.treas.gov.

Julie L. Williams
First Senior Deputy Comptroller and Chief Counsel