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#2118724 - 02/17/17 05:44 PM NMLS number required?
kbaird Offline
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Joined: Dec 2015
Posts: 35
Our bank has historically done so few SAFE Act covered mortgage loans that none of our officers have met the minimum of having originated 5 covered loans to require SAFE act registration and consequently, the bank itself does not have a number either. We have recently hired an officer, however, who does have an NMLS number from working for a previous employer. Is this officer required to include his number on pertinent documents at our bank for loans he is originating, even though he hasn't and might not ever originate more than 5 covered loans at our bank?

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#2119181 - 02/22/17 10:05 PM Re: NMLS number required? kbaird
kbaird Offline
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Joined: Dec 2015
Posts: 35
Bump!

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#2119189 - 02/22/17 10:30 PM Re: NMLS number required? kbaird
Norman Paperman Offline
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Norman Paperman
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In short, no.

I will say that this is one of the few times I have heard of a FI not registering for NMLS. What happens when you bump up against the threshold and a customer wants a mortgage? Do you turn them away?

Pony up the cash and get your FI and MLOs registered.
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#2120140 - 03/01/17 10:01 PM Re: NMLS number required? kbaird
John Burnett Offline
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John Burnett
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Cape Cod
Sorry. But the de minimis exception in section 1007.101(c)(2) is only available to individuals who have NEVER registered. When you hired this individual, your institution become subject to the requirement to itself register.
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#2120141 - 03/01/17 10:03 PM Re: NMLS number required? kbaird
John Burnett Offline
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John Burnett
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Cape Cod
And he remains subject to the registration requirements wherever he works, as long as he works as an MLO. Plus, he has to conform to the rules about providing his number, etc.

Get it taken care of quickly.
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