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#1530165 - 04/01/11 02:01 PM SAFE Act 'Unique Identifier' Question
DonnaS Offline
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I have a question about the SAFE Act. The rule states the following:

§ 34.105 Use of unique identifier.(a) The national bank shall make the unique identifier(s) of its registered mortgage loan originator(s) available to consumers in a manner and method practicable to the institution.
(b) A registered mortgage loan originator shall provide his or her unique identifier to a consumer:
(1) Upon request;
(2) Before acting as a mortgage loan originator; and
(3) Through the originator’s initial written communication with a consumer, if any, whether on paper or electronically.

However, is there anything in the rules or other Regulatory Guidance that specifically indicates that more than one unique identifier may be required for a loan - that is if more than one “MLO” is affiliated with the loan throughout the loan process?

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#1530218 - 04/01/11 02:45 PM Re: SAFE Act 'Unique Identifier' Question DonnaS
ahou Offline
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ahou
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That question came up at our bank too. I couldn't find anything in the Act.
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#1530353 - 04/01/11 03:54 PM Re: SAFE Act 'Unique Identifier' Question ahou
swiggles Offline
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Just pick one. crazy
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#1530364 - 04/01/11 03:58 PM Re: SAFE Act 'Unique Identifier' Question swiggles
#Just Jay Offline
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Well, I wouldn't just pick on as that LO is going to be stuck with that loan for the life of that loan. Heaven forbid that something goes south on the loan later on and someone wants to go back to that bank/LO, I wouldn't want my number tied to it simply for touching it.

I think it would be prudent to assign the 'LO' who had the biggest stake in the loan to the loan, i.e. who got compensated for it, who did the majority work or negotiation, etc.
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#1531132 - 04/04/11 04:49 PM Re: SAFE Act 'Unique Identifier' Question #Just Jay
Dani York, CRCM Offline
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TN
It's not about assigning an MLO ID number to a loan file (except for your FNMA loans). It's about providing the number to the consumer before acting as an MLO. What is supposed to happen is that every MLO that interacts with the consumer when meeting both prongs of the test is to provide their number. In reality, how many employees will actually be acting in that capacity per loan file. More than likely, you will have 1 or 2 depending on how your institution is set up.

For instance, at our bank, our loan assistants generate and provide the early disclosures. They will provide their number to the consumer. The loan officer will also give their number since they are the one selling the loan. For assigning the MLO id number internally, we will use the loan officer's, even though the assistant has also provided theirs.
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#1533605 - 04/08/11 08:50 PM Re: SAFE Act 'Unique Identifier' Question Dani York, CRCM
Will B Offline
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What about revised disclosures or commitment letters. Won't those be gererated by someone else? Those people could be MLOs per the definition becasue they're receiving application information indirectly for the purpose of offering credit terms, and when they issue a commitment letter, or a revised TIL or GFE they'll be offering credit terms.
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#1539943 - 04/22/11 09:44 PM Re: SAFE Act 'Unique Identifier' Question Will B
Lilly1234 Offline
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More related questions...

1) The MLO's name and NMLS# ave to be on the application, correct? All people involved? (Just to clarify)

2) When we take an app over the phone, the Rep discusses the loan then forwards it to the Processors (whom make the decision) and then off to a branch for signing and explanation of all docs. For the application, do we list all three people and their numbers??

3) And another question, can we add an additional page to our loan application that lists the MLO(s) involved in the transaction to cover the "on loan app" requirement?

Thanks in advance!

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#1539946 - 04/22/11 09:51 PM Re: SAFE Act 'Unique Identifier' Question Lilly1234
mmumm Offline
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We are thinking of ordering stamps for our MLO's that have their unique identifier, that way they dont have to keep writing it by hand on various docs - think this would be acceptable/a good investment?

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#1540397 - 04/25/11 08:05 PM Re: SAFE Act 'Unique Identifier' Question mmumm
Tesla Offline
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Sort of a related question--- when does the MLO get their Unique Identifier number? Is it after the CBC is completed?
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#1540559 - 04/26/11 12:16 PM Re: SAFE Act 'Unique Identifier' Question Tesla
mcwrightt Offline
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SkiDoo......the MLO receives an email with their unique identifier number after the institution has completed the batch upload. The second email the MLO receives is their password.

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#1540817 - 04/26/11 03:37 PM Re: SAFE Act 'Unique Identifier' Question mcwrightt
Allshouse Offline
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I understand the MLO's unique identifier must be available to the public but what about the Institution's registered number. Do we need to post that as well as our MLO unique identifiers?

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#1541450 - 04/27/11 01:56 PM Re: SAFE Act 'Unique Identifier' Question mcwrightt
Tesla Offline
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Originally Posted By: mcwrightt
SkiDoo......the MLO receives an email with their unique identifier number after the institution has completed the batch upload. The second email the MLO receives is their password.


Not to sound stupid, but is it called something other than Unique Identifier? I know there is some number in parentheses by their name (six digits), but we weren't 100% sure that was the final Unique Identifier number.
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#1548778 - 05/10/11 03:45 PM Re: SAFE Act 'Unique Identifier' Question Tesla
mmumm Offline
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one of our MLO's registered and said that at the end, it directed them to get fingerprinted, but didnt tell them whether they had to go to a LiveScan place or if they could go to the local police dept and get scanned.

when i spoke with someone at the SAFE Act registry number, they said when the MLO registers it should have checked their address and if it was within 25 miles of a LiveScan site, it should have told them to go there; or if it was further than 25 miles, then it should have sent them a fingerprint card packet in the mail so they could take it to their local police dept.

Has anyone else gone through the registration and what did it tell you in regard to fingerprinting?

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#1548825 - 05/10/11 04:22 PM Re: SAFE Act 'Unique Identifier' Question mmumm
Dani York, CRCM Offline
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It didn't really tell you anyhting. When our MLOs registered they had to dig around on the site to find the fingerprinting info. We registered ours in Feb, so they could have upgraded their communication since then.
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#1548878 - 05/10/11 05:13 PM Re: SAFE Act 'Unique Identifier' Question Dani York, CRCM
Queen Mum Offline
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When putting in your physical address, it brought up the options. Since the closest Livescan place is 2 1/2 hours away, we ordered the fingerprinting kit and went to the Sheriff's office. Four out of the six passed ok and two came back fingerprints illegible. So we had to process and order them new kits and they will have to go have fingerprinting done again.

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#1548880 - 05/10/11 05:14 PM Re: SAFE Act 'Unique Identifier' Question Allshouse
Queen Mum Offline
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Originally Posted By: Allshouse
I understand the MLO's unique identifier must be available to the public but what about the Institution's registered number. Do we need to post that as well as our MLO unique identifiers?


I am wondering the same thing. If we put the MLOs ID number on stationary, do we also have to list the Institutions ID #?

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#1548915 - 05/10/11 05:34 PM Re: SAFE Act 'Unique Identifier' Question Queen Mum
Dani York, CRCM Offline
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TN
There is no requirement to disclose the institution's id number.
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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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#1573888 - 07/05/11 06:56 PM Re: SAFE Act 'Unique Identifier' Question Dani York, CRCM
mmumm Offline
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Santa Cruz, California
We are planning to order stamps for our MLOs (in addition to adding their ID # to biz cards and email sig line) that say: "John Doe NMLS I.D. #:123456". That way they can easily stamp documents, etc with their unique ID#.

Anyone have any suggestions/opinions about this - is that acceptable verbiage to put? Thank You!

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#1573926 - 07/05/11 07:27 PM Re: SAFE Act 'Unique Identifier' Question mmumm
sjlee Offline
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Oklahoma
A stamp with the LO's name and number is the route we are taking too.
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#1574639 - 07/06/11 09:19 PM Re: SAFE Act 'Unique Identifier' Question sjlee
mmumm Offline
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Carotop3, are you putting the MLO's name on the stamp, or just their ID#? Since the ID# has to be on correspondence specifically from that MLO, wouldnt their name already be on the document somewhere?

We are thinking of a relatively small stamp - no larger then 2 postage stamps side-by-side.

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