If a bank has only one MLO, can they also act as the NMLS administrator? I am looking at 103(e)(1)(i)(F)and I get the impression that they cannot. Is there any exception to the rule?

Did you read the preamble to the regulation in the Federal Register? The exemption is dependent upon total full time equivalent employees.

"Required Agency-regulated institution information. The Agencies adopt proposed § .103(e)(1) with the following amendments, discussed below

Paragraph (e)(1) of § .103 of the final rule requires the employing Agency regulated institution to submit certain information to the Registry as a base record in connection with the registration of one or more mortgage loan originators. Specifically, the Agency-regulated institution must provide its name; main office address; business contact information, such as business phone number or e-mail address (not required by the proposed rule); primary Federal regulator; Employer Tax Identification Number (EIN) issued by the Internal Revenue Service; primary point of contact information; and contact information for ‘‘system administrators.’’ System administrators will have the authority to enter data required in paragraph (e) of this section on the Registry and will be responsible for keeping institution information and the list of employees registered with the Registry current. These individuals, however, may not act as mortgage loan originators. The Agencies recognize that some small institutions may not be able to comply with this latter requirement because all of their staff may be registered mortgage loan originators.

Therefore, we have amended this provision to exempt institutions with 10 or fewer full time equivalent employees from the requirement that system administrators do not act as mortgage loan originators. However, this exemption does not apply to a subsidiary of an Agency-regulated institution as the staff at the parent institution could perform this function.

In the Agencies’ experience, institutions with more than 10 full time equivalent employees generally have sufficient staff resources to support the segregation of these functions. The system administrators may delegate their authority and assign as many additional system users as necessary to comply with the registration requirements of the S.A.F.E. Act and the final rule, provided the delegated administrators meet this paragraph’s requirements. While the primary point of contact also can be one of the institution’s system administrators, the institution’s management is responsible for ensuring proper oversight of the system administrator’s activities."

So essentially, if the bank has more than 10 full time employees (and they only have one MLO), that MLO should not also be their administrator.

Makes sense.

Correct. The feeling is there are then enough employees to find someone to take on that role other than an MLO.