With the SAFE Act, how are we required to handle the NMLS number when an originator leaves before their loan closes? Does their number remain on the documents as they were the Loan Originator or are we required to use a different originator number even though they didn't negotiate the loan?
I'm the internal auditor and reviewing compliance with SAFE Act and Reg Z for including unique identifier on loan documents. We originate our reverse mortgages through two investors. The documents are produced through the investor website. Does the NMLS # have to be on the GFE? I'm not seeing it on the GFE for either of our investors. What disclosure documents exactly is it required? (they have on the note, mortgage, application)
Do I need to have my MLO Registration number on any business card I might have for the bank under the SAFE Act?
Two questions related to the recent revisions to Reg Z. 1) Does a business purpose loan partially secured by residential RE now fall under Reg Z? Do you need to have a NMLS license to discuss RE secured products with customers, including abundance of caution liens.
What are the new amendment regulations for the SAFE ACT going forward?
This question is in regards to the SAFE Act and disclosure of the MLO's unique identifier with the initial written communication. If loan is made to an employee of Sr. Management and the MLO is Sr. Management as well, does the requirement still apply? Obviously these employees know each other well, and since the unique identifier is a tool for customers to get info about the MLO would the disclosure of the unique identifier be relevant in this case? Would an examiner cite an Institution for not having disclosed the unique identifier on initial written communication?
Regarding SAFE Act compliance - the "Relation to Other Laws" section on page 9 of the March 2012 CFPB Safe Act guide - seems clear the MLO's NMLS number must be included on the loan application. BUT - if the loan is going to be kept in-house and not sold to the secondary market - is it still necessary to include the MLO's NMLS number on the loan application?
I had a question about publicly disclosing MLOs. I recently did some compliance testing on a bank and noticed that the list provided to us of registered mortgage lenders was longer than those listed on the bank's website. I know that listing MLOs on the financial institution's website is one requirement of the SAFE Act. Are these institutions required to publicly disclose all of the registered mortgage lenders or only those that actually make mortgage loans (in regards to the SAFE Act)?
Does the SAFE Act require us to conduct an annual audit? And if so, what is the Section of the Act that supports this? What does it say?
In regards to the SAFE Act, are we required to include the banks NMLS license number on all correspondence along with the MLO's number?