In regards to the new TRID rules:

I recently attended a Compliance Forum where it was stated that the name of the individual loan officer who is the primary contact for a customer must be stated on the LE & CD exactly as that MLO was registred on the National Registry. ? If this is true, do we have to list full names (example: John Michael Doe) if that is how they were registerd? I can't seem to find this anywhere in the regulation, would someone be able to point me in the correct direction

the individual loan officer who is the primary contact for a customer must be stated on the LE & CD exactly as that MLO was registred on the National Registry

What was this person's regulatory cite for such a claim.

It was something a few Banks were cited on by their Auditors. I was just wondering if there was any power behind that.

1026.37(k) and .38(r) only address the disclosure of the specific NMLS and/or other required licensing number. No where that I can find do they specify the contacts name has to be an exact match of how they are registered. The NMLS and/or other required licensing number would identify the contact in the registrar if needed.

We have also been cited for this in the past. The only thing I can find to support this is in the SAFE Act Examination Guide. Section E.10.

"Select a sample of loan files and compare MLO information to NMLS. Are there any discrepancies between NMLS and the MLO information in the loan files? Examiner note: Use NMLS or www.nmlsconsumeraccess.org."

I believe Reg Z does specify the name as registered, see 1026.36(g)(1)(ii) below:

1026.36(g) Name and NMLSR ID on loan documents.

(1) For a consumer credit transaction secured by a dwelling, a loan originator organization must include on the loan documents described in paragraph (g)(2) of this section, whenever each such loan document is provided to a consumer or presented to a consumer for signature, as applicable:

(i) Its name and NMLSR ID, if the NMLSR has provided it an NMLSR ID; and

(ii) The name of the individual loan originator (as the name appears in the NMLSR) with primary responsibility for the origination and, if the NMLSR has provided such person an NMLSR ID, that NMLSR ID.

(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.

(3) For purposes of this section, NMLSR ID means a number assigned by the Nationwide Mortgage Licensing System and Registry to facilitate electronic tracking and uniform identification of loan originators and public access to the employment history of, and the publicly adjudicated disciplinary and enforcement actions against, loan originators.

1026.36 requirements never entered my mind. Thanks for posting the cite.

Does MLO's name and NMLSR ID need to be on each page of the credit app?

No. This is in the commentary to 1026.36(g):

3. Inclusion of name and NMLSR ID. Section 1026.36(g)(1) requires the inclusion of loan originator names and NMLSR IDs on each loan document. Those items need not be included more than once on each loan document on which loan originator names and NMLSR IDs are required, such as by including them on every page of a document.

Thank you!!

Question along with this-- we are a wholesale lender, so who do we list under the lender's loan officer? It's the mortgage broker's loan officer, not ours- so under mortgage broker we are putting their company name/NMLS and loan officer name/NMLS, and for the lender section we're putting our lender name and NMLS, but are not sure who to list as a named loan officer contact for the lender, especially since the rule appears to show they must be licensed. Any input?

And another question to go along with that... the NMLS system requires the addition of a/k/a - so if I list Billy Smith as a valid aka and that is how the Note/CD/etc read (rather than William Smith as is the principal name) - does that mean that the name matches exactly (as long as it matches an a/k/a - or must it match the "principal" name?

The principal name is probably the best, but consider the purpose of the requirement -- to enable the borrower to access info on the MLO in the NMLS. A match to an "other name" attached to the registration will accomplish that goal, so using the alias or nickname or AKA (whatever you want to call it) should be acceptable, too.

What had your organization opted to use for the Lender's Loan Officer on your wholesale transactions?

Reviving this thread, for the contact information if an LO works from a particular branch, would you put the main address for the Lending Company and the NMLS ID, or the actual branch with the branch's NMLS ID?

3. Address. The address disclosed under § 1026.38(r)(2) is the identified person’s place of business where the primary contact for the transaction is located (usually the local office), rather than a general corporate headquarters address. If a natural person’s name is to be disclosed under § 1026.38(r)(1), see comment 38(r)-2, the business address of such natural person is listed (assuming that such natural person is the primary contact for the consumer or seller, as applicable).