Employees who assist in applications for home equity lines of credit are excluded from the rule, according to NAFCU's handouts.

Loan originators must be licensed under the SAFE Act; however, Bahhur said unlicensed originators can still meet CFPB qualifications if a credit union documents that they have passed a criminal background check, meet credit report standards, and have no administrative, civil or criminal determinations.

Originators must also meet specific financial responsibility, character and general fitness standards.

To determine these standards have been met, Bahhur said credit unions must not only document criminal checks and credit reports, but also search for current outstanding judgments, tax liens, nonpayment or child support, or any pattern of bankruptcies, foreclosures or delinquencies.

Credit unions must also consider any acts of unfairness or dishonesty, and any disciplinary actions taken against the employee, Bahhur said.

No single factor will automatically disqualify a loan originator, the NAFCU compliance attorney said. Rather, an originator's qualification standards must be taken as a whole. An exception would be a conviction for any felony over the past seven years, or conviction of a fraud-related felony at any time, she added.

Bahhur stressed that the regulation only applies to new hires. Loan originators hired before Jan. 10, 2013, are considered to be in compliance with the reg if they passed other screening regulations in effect at their hire date.

Periodic training rules apply to all originators, regardless of when they were hired. Originators must also disclose their name and Nationwide Mortgage Licensing System and Registry ID on loan documents.

Director of Regulatory Compliance Steve Van Beek said the new combined TILA/RESPA disclosures will include a specific place to disclose originator information. However, because the TILA/RESPA rule has not yet been finalized, he said credit unions must disclose the originator information in the loan document.