Do you have any suggestions on how to comply with the SAFE Act NMLS ID disclosure when an application is transferred from one MLO to another? For example, they start the application as a conventional 30 year to be sold on the secondary market and for whatever reason that doesn't work and we counter with a portfolio loan that is then handled by a different MLO.

We have the last MLO handling the file to sign and use NMLS # on the final 1003 or application.
If you start a new application from scratch the MLO handling the new file will use his/her NMLS #s

With our recent updates, we have the ability to designate the MLO/LO that:

Took the application
Responsible for the Note
Responsible for the Deed
Responsible for the Settlement

So, for instance, you could have one LO for the application and an MLO for the remainder.

What if we have a situation where we generated loan documents that include the MLO name & number of the MLO handling the transaction. But on the date of closing, he's out sick!! If another MLO handles the closing, is he required to cross-off the preprinted MLO name & number (from Laser Pro) and write in his own number? Or can we leave the name & MLO # of the original MLO on the Note & T/D?

According to 1026.36(g)(1)(ii), the documents must show the name of the individual loan originator "with primary responsibility for the origination."

In the situation you described, it seems to me that the first MLO is the one with primary responsibility, and it would be his name and information that must appear on the documents.

Tagging on here...We have an investor that has asked us to correct final closing documents with the name and number of the MLO with primary responsibility "at closing". They referred to the commentary in 1026.36(G)(1). They are saying a loan may not close with name and number of the originating MLO if he/she has resigned from the bank prior to closing.

We have never had this come up, is this correct?

Correct. See Comment 36(g)(1)(ii)-1 at http://www.bankersonline.com/regs/12-1026/12-1026-036.html#interp-g