We are planning on having the NMLS ID# on the GFE. I was also going to instruct the MLOs if they are verbally discussing rates they need to give their number out. Is this sufficient for compliance with the act?

We will be posting a listing in each branch of each ID # as well as making them available on request.

How about on our websites?

We are doing:

Business cards
Website
Email signature line
Written correspondence
LO specific marketing pieces

Where or how are you planning on putting it on the GFE?? The GFE doesn't allow for modifications of the form, and will you have room in the originatior name box to write "John Q. Johnson, NMLS ID# 12345678"

We are putting them on the applications and discussing the business card route. (Application - We sell to Freddie and they require)

IMO, you have to have it someplace else earlier than the application, the whole point of the rule being (trying to put myself in the writers shoes here) that the consumer has the ability in check out the MLO prior to choosing to do business with them, which IMo entails deciding to sit down and move forward by completing an application.

How is that objective served if the ID doesn't appear until it is on the app? Furthermore, how often does the borrower get a copy of the app, prior to the closing table anyways.

Thank you.
These are all the same arguments that I keep making.

Gotcha.

We were thinking about putting a sign on each MLO's desk that lists their SAFE #. Would that be "providing?" Similar to the posts above, we are considering adding it to the application and to business cards but it seems to us that the MLO may be "acting as an MLO" before any of that would be given to the customer.

We are planning to post the #'s in our lobby, on business cards, applications and ALL correspondence (email, written letter, etc). As for our website, we don't take applications online, nor do we list any of our staff/officers or their email addresses, however, I am conflicted as to whether we should post them there as well.

Newbie here!!!

I went on the consumer site to search for a NMLS registered person and it says in the disclosure that:

■Does not include individuals working for federally insured depository institutions.

So we are going to provide this number to consumers and they cannot even verify the information.

So if we are FDIC regulated banks do we have to do the NMLS registration?

My understanding is that employees of federally insured depository institutions ("banks") won't have their information available on the Registry until after the July 30th(?) deadline.

If you have people who meet the MLO definition, yes, they (and your bank) will have to register. Banks are excluded from the licensing and continuing education part that state-licensed brokers have to do.

Yes your bank and your MLOs have to register. MLOs who work for banks will not show up in the Registry until after July 29th.

And honestly, the consumer will not look up the number. They don't care. This is just another hoop for us to jump through so politicians will have something to hang their hat on to get re-elected.

I have not heard about advertizing materials or blogs. Our LOs have their own advertizing materials and they are always adding blogs. We are requiring that Marketing confirms that the MNLS numbers is on all advertizing material prior to approval. In addition, we are requiring the LOs to add their NMLS number on their blogs. Is this over kill?

I don't think so, we are also putting the NMLS # on their business cards.

Are you also disclosing the branch ID on the business cards?

The docket says...."We note that the Board has proposed
amendments to 12 CFR 226 (Regulation Z) that would require disclosure of the unique identifier as part of TILA
disclosures, which generally must be provided to a borrower within three business days of the residential mortgage loan application and seven business days before consummation of
the transaction."

So putting the number on the GFE is what we are doing.... but where does it go??? Does the loan officer just write it in at the top?

We are also putting a notcie in the lobby and ion our web site, but keeping it simple! It doesnt say its required other places!

http://edocket.access.gpo.gov/2010/pdf/C1-2010-18148.pdf
(page 20)

I figure the MLO having his/her NMLS number would point the consumer to the right place on the consumer website.

My understanding was that the GFE could not be altered per HUD's guidance. We are adding the NMLS number on our early disclosure cover page.

You could just list it in the lender information box on the GFE with the bank name and address.

We were going to put the NMLS ID on business cards, bottom of e-mail signature, a sign at each desk, on our website under mortgage loans - Is that overkill?

For the signs in the branches and at the lenders desk and on the website are you listing ALL of your MLOs? We have around 100 so..... I could see having each lender with their own sign at their own desk. Is that what others are doing?

For our mortgage loans, we receive numerous loans through our website and the GFE and early disclosures are all automated. They are delivered electronically before the loan is even assigned to a lender so do we have to attach a list of all MLOs with their numbers to our early packet?

We are small and only have 3 loan officers.. we are putting ours in the same places as you and also posting a lobby notice. Figured we have ourselves covered with giving the numbers out... (until they change it!)

In putting it on the website, how are you doing that? We don't list our Loan Officers on our website. We do, however, list bank officers with an e-mail link. Are we going to need a special page to list each MLO and their Unique Identifier?

You don't HAVE to put it on your website. That was just an example of one way to make the numbers available. If you want to put them on your website, then you can do it however you want.

The easiest way to make the numbers available is to provide a list upon request. Less maintenance when you have turnover, etc. And of course the individual MLOs need to give their individual number out however, you prescribe (business card, signature lines, etc).

Your list of officers with an email link wouldn't need the number as the officer has not yet acted as an MLO.