Prior to SAFE Act, commenters have posted that a business card is not a specific advertisement for mortgage loans and that EHL words & logo were not required. Our bank registered every lender who "might" act as MLO. Does the addition of NMLS ID# to business cards now trigger requirement for EHL words & logo(for FDIC banks)?

I'd like to know this too. Thanks!

And ... are you designating on business cards as a NMLS# or a MLO #?

As I've read in previous posts, most banks are stating NMLS#, which is more consumer friendly. A simple google search for NMLS will bring you right to the Registry where a google search of MLO won't bring you to the proper place.

All bank lenders were registered and will now have their number on their business cards. Numbers will be designated as NMLS ID ######. In the past, these cards have not had EHL words & logo on them because there was no reference to mortgage lending or products. The question is whether an otherwise generic business card becomes a form of mortgage "advertisement" by default once the NMLS ID is added, thus requiring EHL.
Any feedback is appreciated.

I don't it qualifies. How doe sthe number itself promote a mortgage product?

I look at the NMLS id number as an identifier only, like a license number or a certification designation. If I have MBA or CRCM or an insurance license listed on my business card, is that, in itself, promoting a product? Or does it just tell people who I am and what I'm qualified to do? I think the number is just an identifier.

Not sure if that's right, just my 2 cents.

FWIW, I agree with Dani.
My personal opinion is that having "NMLS" present does not make the business card an advertisement.

I agree the NMLS # is an identifier--of a person registered to act as a mortgage loan officer. When we think about why a person places an identifier following their name on a business card, whether MBA, CRCM, or NMLS, isn't it to bring attention to it, in essence to "advertise" the designation to everyone who receives the business card? Once the NMLS ID is on the card, can it then be disassociated from promoting the business to which the designation owes its existence? Of course, the easiest path is to put EHL on the business cards and be done with it, but nothing in this business is simple these days.
Thanks everyone for your responses.

does the NMLS # have to be next to the lenders name? We are creating new business cards and they want the lenders photo and name and the FI name on one side, their branch contact informaiton and NMLS # on the other side.

A gray area IMO as the regulation doesn't go into specific details. It tells you when an MLO must provide his/her number (before acting as an MLO, upon request, and with the first written correspondence with the applicant); it doesn't tell you how it must be provided (it can be orally in the first 2 instances). So it really comes down to what an individual examiner thinks of your process. Having said that, if an examiner wanted to nit-pick, i think they could say that the NMLS# needs to be clearly associated with the MLO and that not having the number next to their name isn't clear. Another examiner might not say a word. Obviously, just my two cents.

I can see your point. Thanks

Just to let you guys know what we have done here. We have our company id on all print adds and it is mentioned at the end of all radio spots. Our EHL was changed to also show our company id directly underneath. Our business card do contain the individuals Unique Identifier and we will be adding our new EHL. It is felt that once the card is presented to a customer you are advertising your services.

and as Raitchjay said, there are no specific details....

When I worked for a very large bank we only listed our NMLSR# and they were compliance NAZI's. Because we are required to disclose our NMLSR# I don't feel it will be interpreted as advertizing if it is on a business card.