Thread Options
#2017826 - 06/02/15 11:23 PM NMLSR and other license info
time flies when you're having fun Offline
Gold Star
Joined: Feb 2007
Posts: 289
The commentary to 1026.38(r)-4 requires disclosure of an NMLSR ID number for each person identified in the "contacts table."

The commentary further states that "if the creditor, mortgage broker, or natural person has an NMLSR ID and a separate license number or unique identifier issued by the applicable State, locatility, or other regulatory body with responsibility for licensing and/or registering such entity or person's business activities, both the NLSR ID and the separate license number or unique identifier is disclosed.

I'm perplexed as to what additional license info would need to be obtained from Realtors, settlement agents, Loan Originators. How do we ask for this -- what exactly are we asking for? These entities may have a variety of licenses some of which have nothing to do with mortgage transactions. For example, would a bank need to disclose the bank's FDIC#'s? What if the Loan Originator has a license to sell investments (unlikely, and questionable, I know).

I'm just wondering how much legwork we must go through here and which types of licenses we are looking to disclose. Seems to me only those that relate to mortgage transactions. Thoughts?

Return to Top
TRID - TILA/RESPA Integrated Disclosures Rule
#2017842 - 06/03/15 02:20 AM Re: NMLSR and other license info time flies when you're having fun
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
Per the section by section analysis, the point here is to show that the parties to the transaction are appropriately licensed for the transaction, not anything else they do in their life.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

Return to Top
#2018022 - 06/03/15 05:13 PM Re: NMLSR and other license info time flies when you're having fun
DoubleNickel Offline
Junior Member
Joined: Jan 2013
Posts: 25
We have lenders that do lot loans and do not have an NMLS ID. Under TRID, would we leave the Contact NMLS ID blank and only list the Bank's NMLS ID? I'm hoping management decides for all consumer purpose loans secured by real property to funnel to an MLO and then this would not be a concern.

Return to Top
#2018101 - 06/03/15 07:04 PM Re: NMLSR and other license info time flies when you're having fun
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,598
Cape Cod
The regulation calls for including the ID if the person has one. It does not require that the individual or entity have such an ID.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#2018297 - 06/04/15 01:44 PM Re: NMLSR and other license info time flies when you're having fun
time flies when you're having fun Offline
Gold Star
Joined: Feb 2007
Posts: 289
Thank you Kathleen and John for helping me find my way through this maze -- the vodka isn't helping.

Return to Top
#2018302 - 06/04/15 01:52 PM Re: NMLSR and other license info time flies when you're having fun
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,598
Cape Cod
Nor does tequila, I understand.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#2083703 - 06/16/16 12:14 PM Re: NMLSR and other license info time flies when you're having fun
Compliance101 Offline
Junior Member
Joined: Dec 2014
Posts: 41
We are finding realtors listed on the contract with expired license. What is our responsibility in this case?

Return to Top
#2083713 - 06/16/16 12:38 PM Re: NMLSR and other license info time flies when you're having fun
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,654
The Swamp
Curiously, how do you know? Are you checking them somehow?
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

Return to Top
#2083987 - 06/17/16 04:39 PM Re: NMLSR and other license info time flies when you're having fun
Compliance101 Offline
Junior Member
Joined: Dec 2014
Posts: 41
Yes, Our post closing team checks on them on the state website to verify we have the correct number listed on the CD. We came to find out there were few expired.

Return to Top
#2084239 - 06/20/16 06:24 PM Re: NMLSR and other license info time flies when you're having fun
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 78,971
Galveston, TX
If you were going to do something about it - a post-closing review is not the appropriate time. Why are these not checked before the CD is issued if they are readily available. You need to check your State law regarding what operating as a non-licensed realtor in your State means.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top