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#2010781 - 04/28/15 07:20 PM NMLS ID DISPLAY ERROR
Complianceking Offline
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We received a message from the Doc company that due to a glitch in an update the NMSLR ID was not listed on a few files on the Note and DOT. The deed had already been recorded. Can we correct his error by adding the NMLS number for the LO and the Bank and re-recording the deed? Just to clarify the agent’s name is listed but not the NMLS number.

If an NMLS number was omitted may we correct the document by adding it and re-recording the Deed of Trust to reflect that the NMLS no. has been added? I would venture to say yes, particularly on a Deed, because it is a security instrument and is subject to re-recording due to clerical errors or an omission. As for the Note, it is obviously not a recordable document, so I'm not sure. Any guidance or regulatory reference or link would be greatly appreciated.

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#2011064 - 04/29/15 07:03 PM Re: NMLS ID DISPLAY ERROR Complianceking
Complianceking Offline
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Can anyone please provide some guidance on the above referenced scenario that was previously submitted? I didn't notice any information in the regulation addressing the matter.

Thank you

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#2011073 - 04/29/15 07:17 PM Re: NMLS ID DISPLAY ERROR Complianceking
Dani York, CRCM Offline
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There is nothing prohibiting you from correcting it. You can add it to the deed and re-record....it's just an added expense. As far as the note, you could add it, and if you choose, send a copy to the customer. TBH though, the customer is not going to care. The NMLS number is like the CRA public file....only regulators and secondary market QC people are going to look at it. Customers will not.
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#2011100 - 04/29/15 07:48 PM Re: NMLS ID DISPLAY ERROR Complianceking
Complianceking Offline
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Thank you. I thought that you could re-record it. According to our post closing manager, she mentioned that their investor would not purchase the loan if the Deed was corrected or re-recorded. It's really not considered a correction, because the NMLS number was not included on the documents. Instead it would be an omission. As for the Note, it can be re-drawn to include the NMLS number. I was under the impression that according to the SAFE Act under Regulation Z that you must provide the unique Identifier Number on the legal documents which would include the Note and Security Instrument.

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#2011102 - 04/29/15 07:53 PM Re: NMLS ID DISPLAY ERROR Complianceking
Dani York, CRCM Offline
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Originally Posted By Complianceking
according to the SAFE Act under Regulation Z that you must provide the unique Identifier Number on the legal documents which would include the Note and Security Instrument.


Reg Z requires you to list the NMLS number of the bank and loan originator on the application, note, and security instrument. Customers don't care about it. Regulators look for this low hanging fruit to cite you in an exam. Secondary Market investors will use it to make you buy back the loan or an excuse to not purchase the loan in the first place.
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#2015653 - 05/22/15 12:55 PM Re: NMLS ID DISPLAY ERROR Dani York, CRCM
Sinatra Fan Offline
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Originally Posted By Dani York, CRCM
The NMLS number is like the CRA public file....only regulators and secondary market QC people are going to look at it. Customers will not.


Good analogy. Also unfortunately true of probably 90% of the disclosure information we are required to give to customers.
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#2031063 - 07/31/15 03:24 PM Re: NMLS ID DISPLAY ERROR Complianceking
Snowmann Offline
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How about a secondary market QC review taking issue with the complete name on loan docs not matching with the NMLS database complete name?

"John Fitzgerald Doe" on NMLS database, and "John Doe" typed and signed on loan docs. Is this really an issue, or just an overly sensitive QC auditor?

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#2031141 - 07/31/15 05:59 PM Re: NMLS ID DISPLAY ERROR Complianceking
rlcarey Online
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If the officer is going to use a nickname(s) or an aka(s), there is a place for that in the individual registration process.

If they are not using their middle name - I agree, is it that big of a deal.

Have them show you something that says it is actually required by the investor.
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#2031919 - 08/05/15 07:29 PM Re: NMLS ID DISPLAY ERROR Complianceking
John Burnett Offline
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Regardless of whether the investor in this case actually requires an exact name match, you really don't need this sort of aggravation when it can readily be resolved. Sit your MLO down and have him or her update the NMLS registration to include the second version of his or her name that gets used, and any other version he or she intends to use. This should have been taken care of when the first registration record was set up; the instructions were pretty straightforward. But it's better late than never to get it fixed.

If it's easier, you could think about postponing this update until the renewal window at the end of the year. And judging from the number of times similar questions are raised, it's a good idea to have each MLO review and update his/her "list of names used" while doing the renewals.
Last edited by John Burnett; 08/05/15 07:30 PM.
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#2038753 - 09/16/15 02:14 PM Re: NMLS ID DISPLAY ERROR Complianceking
Compli(cated) Offline
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I'm bringing this thread back to life since we are dealing with the second issue that came up here: the person's full legal name vs. the name they use in their daily life (e.g. Benjamin vs. Ben).

Reg Z requires the name as it appears in NMLS - is the consensus that, as along as "Ben" is added in NMLS as an aka name, it is ok to list "Ben" on the documents? If so, is there a reference for it somewhere?
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#2038786 - 09/16/15 02:48 PM Re: NMLS ID DISPLAY ERROR Complianceking
rlcarey Online
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I'm sure that this information is controlled by some table entered into your LOS system. Why the heck would you not just input the correct name and number as it appears. If you have to input the name and number on each individual transaction, give the input clerks a full listing of how each MLO has to appear on the documents. I'm not sure why anyone has any trouble with this. If the loan officer's are involved, tell them to grow up and use their legal name on legal documents - period - or they can find other employment.
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#2038805 - 09/16/15 03:13 PM Re: NMLS ID DISPLAY ERROR Complianceking
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Thanks for your input, Randy, and I'd love to!

The way our system works - a processor can manually enter the names on all these forms as they are processing them (which is what they have been doing) or we now have a cpability to "attach" the MLOs name to the application and it would auto-populate. With out loan volumes, this shortcut needs to be implemented.

The name that MLO uses for their Windows and core system log-in is what is "attaching" to the application - we allow people to use the shortened versions here since that then goes to the associate directory, phone logs, etc - just easier to not always have to correct people on what name somebody goes by. Another (admitedly ridiculous) obstacle is the fact that our core system has a length limit for log in names and we do have several that would be simply too long.

So, if there is any way that we can use the "aka name," it would be the preferred route. But by your answer I am gathering that maybe it is not an option?
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#2038816 - 09/16/15 03:38 PM Re: NMLS ID DISPLAY ERROR Complianceking
rlcarey Online
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The name of the individual loan originator (as the name appears in the NMLSR)

If the their name and AKA are listed, who is going to argue that it is not correct?
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#2038821 - 09/16/15 03:44 PM Re: NMLS ID DISPLAY ERROR Complianceking
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Well, examiners, for one...

I'm with you on that line of thinking, just was looking for confirmation that it is common practice in the industry and we wouldn't be seen as an "innovator" with this interpretation.
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