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#1691909 - 04/24/12 02:58 PM Unique Identifier Requirements
rachelchri Offline
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I have read somewhere that an MLOs Unique Identifier are required on all loans sold to FHLB (Fannie Mae/Freddie Mac). Is there a requirements for the UI to be on all Mortgage applications?

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S.A.F.E. Act Forum
#1691913 - 04/24/12 03:02 PM Re: Unique Identifier Requirements rachelchri
Matt_B Offline
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It's not required by the SAFE Act, but many/most investors seem to want it on there as part of their overlays.
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#1698592 - 05/11/12 02:01 PM Re: Unique Identifier Requirements rachelchri
rachelchri Offline
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When reviewing the OCC's SAFE Act examination handbook, I came across a section that says "Title XIV, Section 1402 of the Dodd-Frank Act amended the Truth in Lending ACT (TILA) to require MLOs to include on all loan documents any unique identifier of the MLO provided by the NMLS..."

Is this just a proposal, or is this something we should be doing?

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#1698596 - 05/11/12 02:02 PM Re: Unique Identifier Requirements rachelchri
Dani York, CRCM Offline
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It's part of Dodd-Frank, but implementing regulations have not been written yet. You don't need to worry about it until the CFPB writes the implementing regulations. When they do, they will tell us (hopefully) what "all loan documents" means.
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#1698599 - 05/11/12 02:08 PM Re: Unique Identifier Requirements rachelchri
rachelchri Offline
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ok thanks!!!!

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#1698605 - 05/11/12 02:13 PM Re: Unique Identifier Requirements rachelchri
rlcarey Online
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In the CFBP proposal issued yesterday, it appears it will be limited to documents that contain terms of the loan.
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#1698728 - 05/11/12 04:20 PM Re: Unique Identifier Requirements rachelchri
Dani York, CRCM Offline
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Randy, where can I find the proposal?
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#1698736 - 05/11/12 04:27 PM Re: Unique Identifier Requirements Dani York, CRCM
Peach Offline
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I think BOL is having a Webinar on June 5th that might be informative as well. What is coming up in lending. I want to attend.

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#1698838 - 05/11/12 06:35 PM Re: Unique Identifier Requirements rachelchri
John Burnett Online
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Originally Posted By: rachelchri
When reviewing the OCC's SAFE Act examination handbook, I came across a section that says "Title XIV, Section 1402 of the Dodd-Frank Act amended the Truth in Lending ACT (TILA) to require MLOs to include on all loan documents any unique identifier of the MLO provided by the NMLS..."

Is this just a proposal, or is this something we should be doing?


What the exam handbook failed to say is that the amendment to TILA won't be effective until (1) final regulations are issued or (2) January 21, 2013, whichever comes first. The final regulations can include a compliance date that's even later than the January date.
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#1698978 - 05/11/12 09:19 PM Re: Unique Identifier Requirements Dani York, CRCM
rlcarey Online
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Originally Posted By: Dani York
Randy, where can I find the proposal?


You can find a link to it in todays top stories on BOL:

Clarify that only disclosure and closing documents that include loan terms must include the required unique identifiers and the names of individual MLOs, and, for those cases in which multiple individuals (or entities) meet the Dodd-Frank definition of mortgage originator, clarify which MLOs must include their unique identifiers and names on the documents.
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#1698983 - 05/11/12 09:22 PM Re: Unique Identifier Requirements rachelchri
Dani York, CRCM Offline
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Thanks so much!
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#1755245 - 11/05/12 10:32 PM Re: Unique Identifier Requirements Dani York, CRCM
complygirl Offline
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Still no final rules on this correct? Just wanted to doublecheck.

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#1755599 - 11/06/12 07:48 PM Re: Unique Identifier Requirements rachelchri
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Correct.
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#1772879 - 01/04/13 10:31 PM Re: Unique Identifier Requirements rachelchri
Queen Mum Offline
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Do you think this is going to be only the UI# of the Loan Officer taking the application or could all UI# of all loan officers be pre-printed on the applications?

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#1773845 - 01/08/13 07:58 PM Re: Unique Identifier Requirements rachelchri
Cocoloco Offline
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Our system was updated to reflect the U/I for the primary MLO. Any MLO's that followed could be located in the audit trail of the application(say the MLO quit)in backup documentation. We also overkilled and have the U/I on all loan documents from applications to disclosures

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#1773891 - 01/08/13 08:52 PM Re: Unique Identifier Requirements rachelchri
Queen Mum Offline
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Are you meaning that you have the UI for the head mortgage loan officer pre-printed on the application? Does that work when another loan officer actually takes the application?

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#1774134 - 01/09/13 03:45 PM Re: Unique Identifier Requirements rachelchri
John Burnett Online
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I'm reading it to say that the bank designates the primary MLO for each application, and that's what follows the file, along with any additional MLOs tucked away in the audit trail.
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#1774211 - 01/09/13 05:29 PM Re: Unique Identifier Requirements rachelchri
Cocoloco Offline
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Bingo John..The compensation aspect to the MLO who actually "worked" the loan then falls to the line of business.

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#1778345 - 01/21/13 08:01 PM Re: Unique Identifier Requirements complygirl
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Originally Posted By: complygirl
Still no final rules on this correct? Just wanted to doublecheck.
The rules on putting NMLS ID#s on loan documents are within the Reg. Z MLO comp. rule that was posted yesterday to the CFPB's web site. http://www.consumerfinance.gov/regulatio...t-regulation-z/ The #'s won't go on the "Loan Estimate" until the RESPA/TILA integratation final rule is issued. This Reg. Z MLO comp. rule refers to the application, the note, the mortgage. See page 486 of the rule.
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#1788622 - 02/22/13 09:10 PM Re: Unique Identifier Requirements rachelchri
Still Smiling Offline
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Sorry for barging in, but this sounds similar to an issue we are having and wanted to see how others handle this.

Our mortgage division (coorespondent lender secondary market) recently hired 2 Jr loan officers that currently are paid on salary and work under an established loan officer for training, etc. Both Jr loan officers have NMLS numbers. These Jr people handle a typical loan from start to closing, however the established LO is allowed to claim the loan for compensation purposes and therefore the established loan officer NMLS number shows up on final documents and internal systems for future marketing campaigns, etc. I know I don't have to tell you guys how territorial loan officers can be, so I am looking to resolve a fight...

Am I wrong, I see potential problems if a customer has been given more than one loan officer or unique identifier number associated with a particular transaction? There could be liability issues for possible problems that could occur and which officer is responsible?

I haven't been able to find where this is specifically addressed so I would appreciate advice on how you might handle this type situation.
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#1788733 - 02/23/13 01:22 PM Re: Unique Identifier Requirements rachelchri
John Burnett Online
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The number appearing on your systems is whatever you need it to be, but the number appearing on correspondence with the applicant and on loan documents should be that of the MLO handling the application or other aspect of the transaction. Find another way to log who gets credit for the loan.
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#1788858 - 02/25/13 05:07 PM Re: Unique Identifier Requirements rachelchri
Still Smiling Offline
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As always...thanks John
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