Sunday, May 31, 2009

Mortgage originators: it's time for a different kind of exam.

Tons of burdensome and populist regulation will probably hit the banking industry as a knee jerk reaction to this financial crisis. Here is one that is actually useful: mortgage originator rules and registration. Think about it. Securities and futures brokers/dealers/sales people have to be licensed. Here are the various certifications they have to pass (depending on the level and the area) - listed here to make a point:
  • Series 3 - National Commodity Futures Exam
  • Series 5 - Interest Rate Options Exam
  • Series 6 - Investment Company and Variable Contracts Exam (Mutual Funds/Variable Annuities)
  • Series 7 - General Securities Representative Exam (Stockbroker)
  • Series 11 - Assistant Representative - Order Processing
  • Series 15 - Foreign Currency Options Exam
  • Series 17 - Limited Representative (FSA registration)
  • Series 22 - Direct Participation (Limited partnerships) Exam
  • Series 30 - Futures - Branch Office Manager Exam*
  • Series 31 - Futures - Managed Funds Exam*
  • Series 32 - Futures Exam - United Kingdom Representatives*
  • Series 37 - Canadian Module of the General Securities Exam
  • Series 38 - Canadian Module of the General Securities Exam
  • Series 42 - Registered Options Representative Exam
  • Series 44 - NYSE Arca Options Market Maker Exam
  • Series 47 - Japanese Module of the General Securities Exam
  • Series 52 - Municipal Securities Representative Exam
  • Series 55 - Equity Trader - Limited Representative Exam
  • Series 62 - Corporate Securities - Limited Representative Exam
  • Series 63 - Uniform Securities Agent State Law Exam*
  • Series 65 - Uniform Registered Investment Adviser Law Exam (RIA)*
  • Series 66 - Uniform Investment Adviser - Combined State Laws Exam* (Combined 63 and 65)
  • Series 72 - Government Securities - Limited Representative
  • Series 82 - Private Securities Offerings - Limited Representative
  • Series 86 - Research Analyst - Securities Analysis
  • Series 87 - Research Analyst - Regulations
  • Registered Principal Level:
  • Series 4 - Registered Options Principal Exam
  • Series 9 - NYSE General Securities Sales Supervisor Exam - Options
  • Series 10 - NYSE General Securities Sales Supervisor Exam - General Module
  • Series 12 - NYSE Branch Manager
  • Series 14 - NYSE Compliance Officer
  • Series 16 - NYSE Supervisory Analyst
  • Series 23 - General Securities Principal (Upgrade from Series 9 and 10)
  • Series 24 - General Securities Principal Exam
  • Series 26 - Investment Company (Mutual Funds) Principal Exam
  • Series 27 - Financial and Operations Principal Exam
  • Series 28 - Financial and Operations Principal Introducing Broker Exam
  • Series 39 - Direct Participation Programs Principal Exam
  • Series 51 - Municipal Fund Securities Limited Principal
  • Series 53 - Municipal Securities Principal Exam
source: Wikipedia

Real estate brokers must have a license, so do accountants. But the guy/gal who sets you up with probably the riskiest financing that an individual/family can get (5:1 or higher leverage on your real estate investment - your house) didn't need anything. Most people will not end up without a home because of improper stock trades. But bad mortgages are doing it to millions.

So the various bank regulators are looking at a new proposal to deal with the issue. It will be bureaucratic and painful, but it's needed. Here is the overview:
"The OCC, Board, FDIC, OTS, FCA, and NCUA (collectively, the Agencies) are proposing amendments to their rules to implement the Secure and Fair Enforcement for Mortgage Licensing Act (the S.A.F.E. Act). The S.A.F.E. Act requires an employee of a bank, savings association, credit union, or other depository institution and their subsidiaries regulated by a Federal banking agency or an employee of an institution regulated by the FCA (collectively, Agency-regulated institutions) who acts as a residential mortgage loan originator to register with the Nationwide Mortgage Licensing System and Registry, obtain a unique identifier, and maintain this registration. This proposal implements these requirements. It also provides that Agency-regulated institutions must require their employees who act as residential mortgage loan originators to comply with the S.A.F.E. Act's requirements to register and obtain a unique identifier and must adopt and follow written policies and procedures designed to assure compliance with these requirements."
This document is dry and boring. It asks for inputs from the industry and regulators. It's a start.


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