Are we required to provide a list of all MLOs upon request? What's the purpose?

I've worked in a very small bank in a very small town where everyone knew everyone and what they did, whether they admitted it or not. But what if I now work in a huge bank with countless MLOs in almost as many brick and mortar locations, not including the Internet? It would be a super fat and ever-evolving list.

I thought that it was supposed to mean, when an applicant walked through the door and asked me for my MLO ID#.

Nope, you must maintain a list of the MLOs employed by your institution. you may post the list in the lobby if you wish, but at a minimum you must have a list that you can produce upon request. The rationale is that I, as a consumer, can make an educated decision about what MLO I want to use if I don't like the one I have.

Example, my loan is assigned to John ID# 3. I look him up in the Registry, but don't like his profile...maybe I think he doesn't have enough experience. So I ask you for a list of your MLOs and look them all up in the Registry. 1--I can see if you have qualified personnel, and 2--I might just decide that I think Jane ID#7 is more qualified and ask to have my loan handled by her.

Now, will very many consumers actually use the Registry to make educated decisions about where they get a loan....NO! This is all just a way for Washington to say, "Hey, we did something. We thought it would help (to get us re-elected). Blah, blah, blah...."

This is confusing me...the latest information to come from the NMLS says ALL MLOs will have to authorize a credit report that will be reviewed by the state regulator.

So did they make a mistake in saying ALL (which includes financial institution-MLOs) or have state regulators been charged with reviewing ALL MLOs' credit reports?

I took it as the latter because the individual MLO can be employed by more than one company with more than one regulator- but what was your take?

I believe that update is meant for state licensed MLOs. It is not intended for the banks, who are not yet "live" in the system.

That's one of the two things this accomplished. The other thing? Listen carefully. That faint mooing sound you hear? That's coming from the Registry. Based on the proposed fee list (which does NOT include third party vendor costs) this thing is a giant cash cow for someone.

I could use some clarification. The list of required employee information does not include eye color, hair color, height, weight or race but the MU4R does. Are those required pieces of information for MLOs?

Those pieces of info are not required for the Registry's purposes, but for the FBI criminal background checks. The CBC's will be ordered through the Registry.

Thanks!

Kinda a silly question, but.......in regards to keeping a list of MLOs that can be produced upon customer request: we have 4 branches.....should we list all MLOs on all 4 lists, or only MLOs located at that particular branch for that branch's list?

We have 3 branches and are keeping one master list at the main office in HR. If a customer requests one from someone at one of the other branches, the employee will call HR and have the list emailed to the employee who will print it for the customer.

Thanks for the input Dani.

MLOs are required to provide their unique identifier 1) upon request; 2) before acting as an MLO; and 3) through the originator's initial written communication with a consumer.......are these to be exclusive of each other? I mean.....if an MLO meets a prospective borrower, provides them with their unique identifier.....i'm thinking they are good....they wouldn't have to provide it again later. (Not that your procedures in some cases might not overlap; you send an AAN and have it on there for example. Just checking if you are safe if it's provided once and once only in a particular case where the loan is consummated.) Maybe overthinking, but that thought just hit me.

The NMLS has created a "Getting Started" page that provides information that institutions can start to review in anticipation of the federal registry being available. The page indicates that the system should be available on or after 1/31/11. http://mortgage.nationwidelicensingsystem.org/fedreg/Pages/GettingStartedFedCo.aspx

Thanks for the heads up......anybody have a comment on my post above?

Thank you for the link. Guess we can get prepared up until the point it says "Stop".

We are going to include it on their business cards, any marketing materials,emails from the lender, the application, and along with any signature by the lender. That way, we can be sure to comply with the regulation.

I think you might be technically OK with providing it only once, but like others have mentioned, we plan to provide it on numerous documents. Details still being worked out.

Ok....i'm wading thru the information from the link that Reads Regs posted: the bank itself has to get registered first by filing the MU1R out right? Then, when they do, i assume they get the NMLS Unique ID from the Registry, which then individual MLOs will need to put on their own MU4R in that field, correct?

Our system for home equity and home improvement loans is that a special department (backoffice) takes all applications by phone, passes each application to a Central Underwriting Department (also backoffice) and then if approved, the loan is closed at whatever branch location is closest (or chosen) by the customer. It doesn't seem like any of the three....application taker, underwriter or closer.....would be a mortgage loan originator because none meet the two prong test. Could this be right?

Does anyone have an opinion about my question?

Just wondering...who would send out the early disclosures for these loans?

I think this shows just how well they defined MLO's in this ridiculous rule. Refer to Appendix A of the reg and see if you think any of these personnel meet the two prong test.

We're planning to register (unless clarifying guidance is issued) several employees who may not be covered as an abundance of caution.

It would be nice if the Agencies decided to come out with some more specific guidance on who is actually an MLO before the registry goes live.

Same here. We will be registering employees whom I do not regard as MLOs, but who might be considered such under the regulation.

I sent letters to two OTS attorneys asking for clarification on several specific points. I never received any response from either of them.

What seems difficult on this is...who's number goes on the documents?

Especially if you have multiple MLO's in a transaction - Example: Loan processor takes application and provides disclosures, but loan officer actually does most of the "negotiating" with the applicant.