Are bank's required by the SAFE Act to list an individual originator's NMLS ID # on blank applications prior to handing them to a consumer? Often someone will come in to one of our branches to pick up an application, but until they've returned it, an MLO is not assigned to the transaction.
Reg Z lays out some pretty specific requirements, and I don't see any exception for situations where an MLO with primary responsibility has not been identified. Is there an implied exception or does one not exist?
12 CFR 1026.36(g):
(g) Name and NMLSR ID on loan documents. (1) For a consumer credit transaction secured by a dwelling, a loan originator organization must include on the loan documents described in paragraph (g)(2) of this section, whenever each such loan document is provided to a consumer or presented to a consumer for signature, as applicable:
(i) Its name and NMLSR ID, if the NMLSR has provided it an NMLSR ID; and
(ii) The name of the individual loan originator (as the name appears in the NMLSR) with primary responsibility for the origination and, if the NMLSR has provided such person an NMLSR ID, that NMLSR ID.
(2) The loan documents that must include the names and NMLSR IDs pursuant to paragraph (g)(1) of this section are:
(i) The credit application;
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Thanks.