Skip to content
BOL Conferences
Thread Options
#1782121 - 02/01/13 04:56 PM MLO #
SUSANE1 Offline
Platinum Poster
Joined: Mar 2008
Posts: 808
is bank required to post MLO # on website?

Return to Top
S.A.F.E. Act Forum
#1782128 - 02/01/13 05:08 PM Re: MLO # SUSANE1
Matt_B Offline
Diamond Poster
Matt_B
Joined: Sep 2011
Posts: 1,648
A CU, Where Regs Don't Apply
Required, no. You are required to have a list available upon request, and many places have chosen to have them on the website as one of the methods of accomplishing this however. We are one that does that.
_________________________
Someone's about to get horned!

Return to Top
#1789564 - 02/27/13 03:01 PM Re: MLO # SUSANE1
Combustible Offline
Diamond Poster
Joined: Dec 2008
Posts: 1,268
Would a list of MLOs including their Unique Identifiers along with an application suffice as the first notification?

Return to Top
#1789597 - 02/27/13 03:39 PM Re: MLO # SUSANE1
raitchjay Online
Power Poster
Joined: Oct 2009
Posts: 9,088
OK
So long as it was clear to the applicant which LO they were going to be dealing with, i would say it would be ok. Giving out the UI in that first instance can be as simple as the LO giving it verbally though.
_________________________
I'm fixin' to fix that.

Return to Top
#1789615 - 02/27/13 03:55 PM Re: MLO # SUSANE1
Combustible Offline
Diamond Poster
Joined: Dec 2008
Posts: 1,268
I see. For a bank originating in house loans as well as secondary market, is it required to have the MLO write their MLO# on the application for a loan the bank will be putting on their books? LOs are telling us that's only necessary for secondary marketing.

Return to Top
#1789634 - 02/27/13 04:09 PM Re: MLO # SUSANE1
raitchjay Online
Power Poster
Joined: Oct 2009
Posts: 9,088
OK
As of right now, that's a Fannie/Freddie requirement, that's true. However, as of January 2014, Sec. 36 of Reg. Z is going to require that on consumer loans secured by a dwelling as well.
_________________________
I'm fixin' to fix that.

Return to Top
#1789691 - 02/27/13 05:36 PM Re: MLO # SUSANE1
Combustible Offline
Diamond Poster
Joined: Dec 2008
Posts: 1,268
I see. For a bank originating in house loans as well as secondary market, is it required to have the MLO write their MLO# on the application for a loan the bank will be putting on their books? LOs are telling us that's only necessary for secondary marketing.

Return to Top
#1789695 - 02/27/13 05:45 PM Re: MLO # SUSANE1
Dani York, CRCM Offline
Power Poster
Dani York, CRCM
Joined: Apr 2005
Posts: 3,663
TN
You might as well start doing it now on in-house loans as it will be required under Reg Z in January 2014.
_________________________
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.

Return to Top
#1805195 - 04/16/13 07:27 PM Re: MLO # SUSANE1
Sci_Comply Offline
100 Club
Sci_Comply
Joined: Sep 2011
Posts: 189
I had another question. It seems like overkill to me, but we have their MLO #'s on their business cards, email signature lines, and all MLO related paper documents.

One of our lenders is at a conference this week and said that a regulator told them they now have to have it on their voicemail messages. Really? Has anyone else heard this as well?

Return to Top
#1805198 - 04/16/13 07:32 PM Re: MLO # SUSANE1
raitchjay Online
Power Poster
Joined: Oct 2009
Posts: 9,088
OK
No and i think that statement can't be backed up by anything found in the SAFE Act itself. "Before acting as an MLO" is seemingly the first requirement to give the UI, and there's plenty of opportunity after a voice mail message to give it and still not yet have acted as an MLO.
_________________________
I'm fixin' to fix that.

Return to Top
#1805476 - 04/17/13 03:14 PM Re: MLO # raitchjay
DCollins Offline
Platinum Poster
DCollins
Joined: Oct 2001
Posts: 707
Are we required to list NMLS numbers on our loan ads for mortgages? We were told when we first implemeted the SAFE Act that is was not required on ads, however we had an online compliance service tell us we should be including either the bank's number or if the ad has one of our lenders in it, it would be their number.

Return to Top
#1805486 - 04/17/13 03:21 PM Re: MLO # SUSANE1
raitchjay Online
Power Poster
Joined: Oct 2009
Posts: 9,088
OK
If you have your LOs listed on your ads, then yeah, i can see the argument that the NMLS numbers should be there (i guess the argument would be that the ad is a proxy for the LOs "acting as a mortgage loan originator"). If there are no LOs listed, i see no requirement to have them listed or have their NMLS numbers with them. The LOs would not have tripped any NMLS number disclosure requirements yet. That's the way i see it anyway.
_________________________
I'm fixin' to fix that.

Return to Top
#1805491 - 04/17/13 03:26 PM Re: MLO # SUSANE1
Dani York, CRCM Offline
Power Poster
Dani York, CRCM
Joined: Apr 2005
Posts: 3,663
TN
And the bank's number is never required to be disclosed under the SAFE Act....unless your purchasing investor banks want it on the app.

Tell your consultant to go back and READ the SAFE Act!
Last edited by Dani York, CRCM; 04/17/13 04:22 PM. Reason: clarify
_________________________
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.

Return to Top
#1805520 - 04/17/13 03:57 PM Re: MLO # SUSANE1
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
The institution's name and NMLS number AND the MLO's name and NMLS number will be required on certain loan documents beginning January 2014, under new paragraph 1026.36(g).
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top

Moderator:  Andy_Z, John Burnett