We have a loan workout officer dedicated soley to loans that are on non-accural or heading that direction.

That officer does not have a NMLS number. If that officer is working with a consumer cusotmer on a residential mortgage, can he do a 60 - 90 day extension or work with the borrower to exit the relationship?

Sometimes these loans are close to or at maturity by the time they head to workout.

Any thoughts on if he can handle the negotiations without a NMLS number?

Refer to Reg G Appendix A for examples of what does and does not trigger the rules. The following does not - within that category the lender would need to be registered. Outside of it, registration whould be required.

(vi) Receiving information in connection with a modification to the terms of an existing loan to a borrower as part of the covered financial institution's loss mitigation efforts when the borrower is reasonably likely to default.