Mon, Dec 16, 2013
As 2013 winds down, there are still a few compliance requirements that credit unions need to complete before the New Year arrives. Credit unions should make sure that their Mortgage Loan Originators (MLOs) under the SAFE Act are registered/renewed, a SAFE Act audit has occurred and their ACH audit has been completed.
The renewal period for credit unions and their MLOs registered under the SAFE Act began on Nov. 1 and will run through Dec. 31. Credit unions should check their NMLS records to determine which MLOs need to renew their registration (MLOs that registered for the first time within the past six months will not need to renew now) and ensure that those renewals are completed before the deadline.
Credit unions must renew their own registrations before they can submit the renewals for their MLOs. MLOs that do not renew by Dec. 31 will no longer be allowed to act as an MLO until their registration is renewed.
In addition to the MLO renewal, there are two audits that credit unions should ensure are completed or are near completion. Credit unions are required to complete an ACH audit and a SAFE Act audit annually.
The SAFE Act requires independent testing of a credit union's program on an annual basis.
NACHA also requires an annual audit of a credit union's ACH program.
Both audits must also be completed by Dec. 31.