And to clarify, the check digit is the reason for the math for the ULI.

I'm hoping that our software vendor comes up with a check digit for us. If not I may begin to explore alternate career options.

That's kinda what I'm thinking, too. Although if TRID has been anything to go by I probably shouldn't put that much faith in the software folks.

I have to agree with you RR Becca. Although the last minute changes by the CFPB did not help the matter either.

Is anyone taking the position that the ULI needs to be reflected on customer facing documents (eg LE and CD)?

I don't think the LE/CD have enough space on the loan number filed to accommodate a 45 digit number.

Thanks TMatt87, what about the ULI following the loan through a banks/ervicers different systems/platforms, ie origination-> servicing-> loss mit -> collections?

I'm curious about this to, do you think this new ULI number will become the loan number that appears on documents, or will it just be used in the background for HMDA reporting purposes? There is nothing in the HMDA rule or any other rule that says this particular ULI needs to be listed or used anywhere but for HMDA reporting purposes, but I'm wondering if it will be easier to include it as your new loan number of everything.

Curious to hear what people are thinking around this. Thanks

I can't see the HMDA ULI being used as the loan number. I'm willing to bet that no loan servicing platform in the world can handle a 45-digit account number. At best, the ULI would have to be truncated to fit within the servicing platform constraints, and to be a uniquely identifiable number.

Under the current HMDA, we have never used the application number as the loan number. It has never caused a problem.

It will be very important for banks to develop a solid cross reference system. Otherwise, when you query your new loan database or your application database for non-originated loan applications at the end of the year in order to determine that you captured all reportable loans, you are going to be in a world of hurt.

Vendors are looking at this now re how to handle and may very well add a field.

Theoretically, a ULI can be recreated at any time (LEI, ap/loan number, and check digits) but that brings accuracy into play each time it is recreated.

Your ap/loan number can never be reused, even twenty years down the road. Also, if banks are sold, a history of the LEIs used in the past will be needed to recreate the correct ULI.

Think this through carefully and check with your vendors. They are evaluating this now.

We are trying to apply for our LEI number using the link above and the charge is going thru the Netherlands. We got a call from the credit card company asking us if this was a fraudulent transaction.
Has anyone else applied for the number and had any problems? Thanks for any information you can give me.

Per the FAQs:

Please note that the holding company of the GMEI utility is "Business Entity Data B.V.", which is located in the Netherlands.

https://www.gmeiutility.org/frequentlyAskedQuestions.jsp

Additionally, the wire instructions state that if you pay by wire, it goes through the Netherands (this is an international numbering system) so it makes sense that the card payments would do so as well.

https://www.gmeiutility.org/Attachments/GMEI_Utility_Wire_Payment_Instructions_USD.pdf

Thank you so much for the information Kathleen.

It is my understanding that the GSEs will be looking for this ULI to be placed on the mortgage documents in order to ensure future salability of each loan.



So, this may not include the CD/LE, but we believe (at least for now) that this would have to include the Note and Mortgage for a GSE transaction (and likely portfolio transactions if there is even a remote possibility of a future sale). We also believe that there would have to be a place within any servicing system to retain this ULI number. But the retention is not as much of an issue as the calculation (it should be just a 45 character text field such as the address - so easy for me to make this sound simple).

But the calculation of the check digit is the real challenge for us. We were originally going to have the HMDA software vendor create the ULI, but that would create some Rube Goldberg process in which we would create the application, send the data to the HMDA software vendor (or NASA) for the ULI (or as we are calling it the UHHHHLLLLLI), but now we realize that the up front LOS must have this number for the note and mortgage (at a minimum).

Not sure if we will be there in time, but we are trying and that is the process we are working towards. Curious if anyone else is taking a different approach.

(and we couldn't use the respondent id because??)

It is my understanding that the GSEs will be looking for this ULI to be placed on the mortgage documents in order to ensure future salability of each loan.

Just curious, what has led you to believe this statement?

Conversations with our folks from our secondary market group.

I've not heard anything about the ULI needing to be on a Note or Mortgage, so I'd appreciate any additional information about the source of your secondary market group information.

I sure hope so!

If we end up going with Quest Soft software they stated they will generate the check digits...so that was a good thing.

The ABA had a recommended provider for the LEI registration. It is CUSIP Global Services. I think it is the only American company issuing the registrations. Website is www.cusip.com

Quest Soft said they would come up with our check digit for us if we went with them.....so that will help tremendously!!