Would like to poll other banks regarding who is registered with the NMLS as an MLO. Are banks registering anyone who ever was registered in the past, or just anyone currently originating residential mortgages? I'm asking because our commercial lending department is growing. Some of our new commercial lenders were residential lenders in past lives. If a new commercial lender is hired in your bank, are you transferring the NMLS registration that they may have used many years ago in a prior job or just letting the registration remain inactive within the registry?

Bottom line, are only MLOs active within the registry, or are banks registering anyone who may have in the past, or may someday in the future, originate a mortgage?

Then....the next question becomes...If anyone who was ever an MLO gets to remain "active" in the registry, what kind of training program are you requiring? For example, if a commercial lender remains active because at one time he/she was a residential lender, does that commercial lender need to continue to receive training in areas such as RESPA and TiLA (which may not be necessary for a true commercial lender)?

What about warehouse lenders? Are they registered and do they participate in Reg Z and RESPA and HMDA training?

Thanks in advance for weighing in on this. I appreciate it

We only register those who are currently involved in mortgage transactions. To keep a registration active for someone who doesn't touch consumer loans would be a waste of money, IMO.

Just remember that the de minimis exception doesn't apply to those that were previously registered.

A couple of thoughts from a non-lender:

It seems to be smart to maintain an active registration if there's any possibility the individual may do something that triggers MLO status. Let's face it: In a lot of banks a commercial lender may touch a residential loan from time to time for a good commercial borrower or some other reason.

As for the training, what you absolutely DON'T want is a commercial lender who touches a residential loan and screws it up because his/her skills are [wanting/stale/undeveloped/gone/other].

commercial lender who touches a residential loan and screws it up because his/her skills are[wanting/stale/undeveloped/gone/other].

Isn't this the definition of commercial lender?