Q: In Regulation G, what must an institution do to maintain and update the registry?
Registration – 12 CFR 1007.104(b)
A covered financial institution must require an MLO employee to register with the Registry, maintain this registration, and obtain a unique identifier. A covered financial institution must also confirm each MLO’s employment status once the MLO submits registration information to the Registry and before the registration is activated.
Within 30 days of the date an MLO ceases to be an employee of the institution, the institution must notify the Registry of that fact along with the date the MLO ceased being an employee, so that consumers searching for an MLO in the publicly available consumer access portal will know that the MLO no longer has a relationship with the institution.
Renewal and Updates – 12 CFR 1007.103(e)(1)(iii) and (iv)
A covered financial institution must update the information it submitted to the Registry during the annual registration renewal period and must confirm the registration information provided by MLO employees during this period. An institution must update the required institution information provided to the Registry within 30 days of any change in such information.