On January 31, 2011, the following federal agencies – Office of the Comptroller of the Currency; Board of Governors of the Federal Reserve System; Federal Deposit Insurance Corporation; Office of Thrift Supervision; Farm Credit Administration; and National Credit Union Administration – jointly published a notice on their respective websites announcing that the initial registration period for Federal registrations required by the S.A.F.E. Act and the federal agencies’ implementing rules (see our memorandum issued July 28, 2010) will run from January 31, 2011, through July 29, 2011. The federal agencies will soon publish the official notice about this initial registration period in the Federal Register. This joint notice applies to residential mortgage loan originator employees of banks, savings associations, credit unions, and Farm Credit System institutions as well as certain of their subsidiaries that are regulated by one or more of these federal agencies, and notifies these employees to register with the Nationwide Mortgage Licensing System and Registry (NMLSR) and obtain a unique identifier from the NMLSR, in accordance with the requirements of the S.A.F.E. Act and the federal agencies’ implementing rules, on or before July 29, 2011. After this initial registration period expires on July 29, 2011, any existing employee or newly hired employee of a federal agency-regulated institution who is subject to the registration requirements will be prohibited from originating residential mortgage loans without first meeting such requirements. Further information regarding the registration process is available at the NMLSR’s website: http://mortgage.nationwidelicensingsystem.org/fedreg/Pages/default.aspx. This memorandum is for informational purposes and is only a summary of the notice. You may read the complete notice published by the federal agencies at the following website:http://www.federalreserve.gov/newsevents/press/bcreg/bcreg20110131a1.pdf.

Complete Memorandum