We have loan clerks, who type and process loans. They often "hand out" applications after brief conversation with the customer, explaining the application packet. They cannot set rates or terms, they simply provide the customer with a rate sheet. They may enter a conversation about what rate/term might be best for the customer, but they don't "negotiate" the rate-they simply explain it EX: adjustable vs. fixed vs ballon.

The customer then brings the application packet back once the information is filled out. S/He may talk to the same person or to a loan officer. That person then assists the customer in finally choosing a rate/term.

My question is this. If a loan clerk hands out the application and another person ends up actually taking the application, whose ID number will go on the paperwork?

Thanks

I think there are actually several questions bundled in there--are your clerks delivering disclosures such as the TIL or GFE? Are you registering them as MLOs? As far as whose unique identifier to provide to the consumer, i think it depends on how you answered the above questions. If both your processors and your loan officers meet the two-prong test and are thus both registered, i would initially provide the unique identifier for any who would be working on that loan application (typically, you would think, the one loan officer and the one loan processor who they are working with).

They typically do not provide the TIL/GFE-(but they might-the never say never theory) They are completed by another that does not talk to customers at all. They will all be registered. So the level of assistance provided, does not matter-they should all be listed-anyone who works on the file? In the end, that could be several people. Or what is the cutoff-when have they crossed the line and need to be listed?

They need to meet the 2 prong test of accepting applications and negotiating loan terms (although that sounds too simplistic....you need to review what the regulation says IS and IS NOT an example of doing both) in order to need to be registered.

How is everyone disclosing to the customer at origination who the MLO's are and their number(s)? Are you simply putting it on the 1003 or a separate sheet/form? Does anyone have a sample of what they will be using?

Bump!

We are not putting any MLO unique identifiers on the 1003. Each MLO will be required to include his or her unique identifier in the signature of his or her emails, and in his or her initial written communication with a customer.

The Federal Housing Finance Agency (FHFA) has directed Fannie Mae and Freddie Mac to require all mortgage loan applications to include the mortgage loan originator’s unique identifier.

So as long as you never plan on selling these loans to those entities, I guess it would be OK.

We don't, and have no plans to do so. We also have our applications on our web site, available for download by an applicant and completion. We could not put the unique identifier on that form, since we have no way of knowing which MLO might receive the completed application.

Couldn't you solve the problem by having the MLO who ends up handling the file put their identifying # on the final application? That way if five years from now you end up selling on secondary, the # is there.

We don't produce a final application, since we portfolio everything. But that is something that we will have to keep an eye on as we go. It is entirely likely that several MLOs may handle an application at some point in the process. Do we put all the unique identifiers on, or just pick one? I don't pretend to know the answer to that one.