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#1506917 - 02/08/11 09:44 PM Unique Identifier
rachelchri Offline
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The final rule states that the unique identifier needs to be provided:
1. Upon Request
2. Before Acting as an MLO, and
3. Through originator's initial written communication with a consumer.

When would the MLO need to provide their ID# to comply with the "Before acting as an MLO". Before issuing an application? I'm confused...

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#1507082 - 02/09/11 02:13 PM Re: Unique Identifier rachelchri
Many Hats Offline
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Orlando, FL
I had a similar question from a lender....."am I supposed to take a call for a mortgage loan that's transferred from the branch CSR and say - this is Joe Schmoe, my NMLS ID is 12345567, how may I be of assistance?"

I know it's ridiculous, but it was a legitimate question.

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#1507090 - 02/09/11 02:26 PM Re: Unique Identifier Many Hats
Dani York, CRCM Offline
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Dani York, CRCM
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TN
The key to it is that the ID # is provided before acting as an MLO.

At the time the application is taken the employee has not yet acted as an MLO. At that point they have only completed one part of the 2 prong test. The ID # wouldn't have to be given until the MLO also offers or negotiates credit. To me the earliest that might happen is when the GFE is sent. The ID # could be included on the GFE or on a business card that is enclosed with the GFE.

If you did have a case where you have an instant approval, then you could give it verbally on the phone.
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#1507097 - 02/09/11 02:33 PM Re: Unique Identifier Dani York, CRCM
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Makes sense...sure glad it's a two prong test then. smile

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#1507314 - 02/09/11 05:11 PM Re: Unique Identifier Many Hats
rachelchri Offline
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Posts: 165
Thank you for clarifying this for me! The whole thing gets confusing. Do we know exactly what consumers will be able to view about a MLO on the registry? Alot of our MLOs are concerned about there being too much information on the registry for anyone to view.

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#1507418 - 02/09/11 06:16 PM Re: Unique Identifier rachelchri
Dani York, CRCM Offline
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Dani York, CRCM
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TN
Best way to find out is look someone up that's in there now. Go to the consumer site and lookup a "Smith". To my knowledge, no personal info is listed (ie home phone and address, SSN, DOB, etc).

Consumer Access Site:
http://www.nmlsconsumeraccess.org/

Regardless, they have to register, so it really doesn't matter what info shows since the rule is final. If the MLO wants to continue working as an MLO, they're just going to have to go with it.
Last edited by Dani York; 02/09/11 06:18 PM.
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I can't herd the cats anymore, so I just set up the electric fences and let them fry when they stray out of bounds.

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#1507457 - 02/09/11 06:35 PM Re: Unique Identifier Dani York, CRCM
#Just Jay Offline
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Cheeseheadland
Originally Posted By: Dani York
The key to it is that the ID # is provided before acting as an MLO.

At the time the application is taken the employee has not yet acted as an MLO...


Not that I want to get into splitting hairs, but if your job is to origate loans and you have the ability to discuss and negotiate rates, then you are acting as an MLO whether you discussed a rate or not.

I think it is silly to think that a customer will call and provide app details, but not expect to discuss rates. In our market, that customer is eager to lock in that rate while on the phone.

Now, will the customer be savy enough to know to ask for the Identifier, or even care to: probably not. I think it is important to be able to document in your procedures either when or how you offer your identifier.
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#1507633 - 02/09/11 08:12 PM Re: Unique Identifier rachelchri
MollyMacMe Offline
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OH
Originally Posted By: rachelchri
Do we know exactly what consumers will be able to view about a MLO on the registry? Alot of our MLOs are concerned about there being too much information on the registry for anyone to view.


Our legal counsel advised that the following MLO information will not be available for public viewing on the Registry
o Home address and home contact information (telephone and email)
o Social Security number
o Gender
o Date and place of birth
o Fingerprints
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#1507667 - 02/09/11 08:50 PM Re: Unique Identifier MollyMacMe
QCL Offline
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NW IL
How can your legal counsel know that when the NMLS folks on the training call today stated that what will and won't be available has not yet been set in stone?

He advised those on the call to check out the consumer site and said while he expects the federal consumer registry to be similar, there could be changes.

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#1507700 - 02/09/11 09:20 PM Re: Unique Identifier QCL
Cloud9 Offline
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I keep getting questions about where the unique identifier has to be. I don't see that it's required on any specific document, like the GFE, etc. Is that correct? I realize some of the software and forms companies have included space for it on the application, gfe, but I don't think it's required. I assumed that we would put the identifier on business cards, or on our introduction letter to the applicant. Does anyone disagree with this? Thanks.

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#1507710 - 02/09/11 09:29 PM Re: Unique Identifier QCL
MollyMacMe Offline
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OH
Originally Posted By: QCL – MamaBEAR
How can your legal counsel know that when the NMLS folks on the training call today stated that what will and won't be available has not yet been set in stone?

He advised those on the call to check out the consumer site and said while he expects the federal consumer registry to be similar, there could be changes.


Good question, MamaBear. And, Thanks for the information. I'll have to go back to her to determine where she got her information.

We attend our first of the four NMLS training session on 2/18. Sounds like it will helpful.
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#1507743 - 02/09/11 09:45 PM Re: Unique Identifier Cloud9
QCL Offline
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QCL
Joined: May 2002
Posts: 6,259
NW IL
Originally Posted By: Cloud9
I keep getting questions about where the unique identifier has to be. I don't see that it's required on any specific document, like the GFE, etc. Is that correct? I realize some of the software and forms companies have included space for it on the application, gfe, but I don't think it's required. I assumed that we would put the identifier on business cards, or on our introduction letter to the applicant. Does anyone disagree with this? Thanks.


One place = Loan Applications - we sell to Freddie Mac and those applications will be required to contain the indentifier.

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