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#2012339 - 05/06/15 02:07 PM CFPB's Reg Z Program
Combustible Offline
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We're using CFPB's exam procedures, and they ask if the MLO's and the bank's NMLS# are on the note and security agreement. I know it isn't effective until 8/2015, so should I write up if I find any prior to the effective date? Our docs are set up and the bank's number is hard coded, but for the MLO the docs have two blank lines for the MLO to complete with NMLS#s. I know different regulators have quirks and don't want to be criticized for not following their program, so just wondering what I should do in the event an MLO hasn't complied.

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#2012378 - 05/06/15 03:19 PM Re: CFPB's Reg Z Program Combustible
ahou Offline
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ahou
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It is already required on the note & security agreement. It will be also be required on the LE and CD on Aug 1st
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#2012388 - 05/06/15 03:31 PM Re: CFPB's Reg Z Program Combustible
Combustible Offline
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Not sure was an LE or CD is?

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#2012390 - 05/06/15 03:34 PM Re: CFPB's Reg Z Program Combustible
NSF, CRCM Offline
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NSF, CRCM
Joined: Apr 2013
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VA
LE = Loan Estimate and CD = Closing Disclosure.

These are the new integrated disclosures coming in to play on 8/1/2015.

Read through 1026.37 and 1026.38 for more information
Last edited by NSFW; 05/06/15 03:36 PM. Reason: Added more comments
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#2012395 - 05/06/15 03:40 PM Re: CFPB's Reg Z Program Combustible
Combustible Offline
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Aha, thanks. According to BOL's Reg Z 1026.36(g):

Editor's Note: Effective August 1, 2015, paragraph (g)(2)(ii) is amended to read as follows:
(ii) The disclosures required by § 1026.19(e) and (f);
(iii) The note or loan contract; and
(iv) The security instrument.

I take that to read it is not in effect yet?

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#2012401 - 05/06/15 03:50 PM Re: CFPB's Reg Z Program Combustible
NSF, CRCM Offline
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NSF, CRCM
Joined: Apr 2013
Posts: 410
VA
Currently 1026.36(g)(2) reads as:

(2) The loan documents that must include the names and NMLSR IDs pursuant to paragraph (g)(1) of this section are:

(i) The credit application;

(ii) [Reserved]

(iii) The note or loan contract; and

(iv) The security instrument.

After 8/1/2015 it will read:

(2) The loan documents that must include the names and NMLSR IDs pursuant to paragraph (g)(1) of this section are:

(i) The credit application;

(ii) The disclosures required by § 1026.19(e) and (f);

(iii) The note or loan contract; and

(iv) The security instrument.

So currently this information has to be on the credit application, note and security instrument.

_________________________
It is better to act cautiously beforehand than to suffer afterward.

The answers I give are my opinions. Not legal advice.

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#2012404 - 05/06/15 04:00 PM Re: CFPB's Reg Z Program Combustible
Combustible Offline
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Posts: 1,268
Ok, I get it now. Thanks so much! Really am glad I asked!

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