We have 2 banks under a holding company. Bank A has a secondary market department. Bank B has been primarily commercial and interested in doing mortgages. Bank B has hired 2 MLOs and had them registered on NMLSR. Rather than having Bank B hire additional back office staff, they use Bank A software and Bank A closes the loans and sells on the secondary market. Bank A sends the premium made on the sale of the loan back to Bank B.

One of the problems that has come up is the investor buying the loans is saying that this is a mortgage broker situation especially with a Bank A MLO and the NMLS # of Bank B. Bank B is willing to go through the registration process to add Bank B as an employer with the NMLSR, so that the MLO and bank will match up.

Would this clear up the mortgage broker issue so that Bank B would not have to list the premium when calculating points and fees for HCML?

Are there any other issues that we need to worry about between the two banks? (Privacy notices have already been adjusted for sharing between the two banks and opt out procedures.)

You probably need to hire a consultant that specializes in this type of operation. Personally, I have dozens of questions that I would want answered.