Hello - this is a Reg Z and SAFE act question.

My understanding of §1026.36(g)(1)(ii) is that the Loan Originator’s name must exactly match how
the name appears on the registry.

For instance if the NMLS shows “Johnathan Smith Doe”, the documents need to have the name
listed the exact same way.

For example – the NMLS site shows the name as follows:

· NMLS Listed Name: “Johnathan Smith Doe”
· NMLS Other Name: “John Doe”
· NMLS Prior Legal Name: “Johnathan Doe”

May the documents only state, “Johnathan Smith Doe”, or are the other two versions acceptable?
(or just the other name and listed name)

Please let me know. Having a debate with our sales staff on this. Thank you!

The idea is for the consumer to be able to search them on the NMLS website. I think they all work, but what is the big deal? Isn't this normally preloaded in your doc prep system based on NMLS number selected?

It was preloaded - but whoever preloaded it used "other names". They don't want to change the names in the LOS to match because it would now cause reporting errors.

The Reg isn't clear on this matter. If you take it at face value it merely states "As the name appears in the NMLSR".

I'm not trying to make a big deal of it, but I think the conservative route is to use the name exactly as it appears. Don't want to spend too much time fighting this battle with the department but I cant find additional guidance anywhere.

Thank you Randy!

§1026.36(g)(1)(ii)

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.

I really didn't mean that you were making a big deal about it - I figure it was the loan officers that wanted to use their nickname Skip instead of Clarence. I just don't understand this fascination that some people have where they don't want their legal given name to appear on documents that require their name to appear by Federal regulation. You aren't the first to have to battle this issue and I agree with you, but like you said, it is not exceedingly clear.

I've had this battle too! To the MLOs defense, he had quite the embarrassing legal name and preferred "Bo". We've always requested they just update the nmlsconsumeraccess website to include other names they may be addressed by and never really pushed the issue. It's our general policy to include their NMLS info with everything so they can be researched one way or another.

Thank you both. Randy I meant big deal with the LO's - there are certainly bigger fish to fry

Appreciate the information.

im tempted to ask what the actual legal name was Gila haha

Beauregard? Boniface? Bonnie Prince Charles? B.O. Plenty (think Dick Tracy, old-timers)?

Bogart
Bagden
Bohemond
Bolivar
Bolton
Bonamy
Bonar (that could be the one!)
Bond (as in Bond James?)
Boris
Boruch
Boston
Bosworth
Bourbon
Boyd
Boyton

Actually, the real name is after an abusive soul artist the town I lived in memorialized. Good luck - but I feel I'm losing anonymity as I type!

AH... its good to get a laugh in the compliance world

My degree is from a private conservative Christian university. I had a couple hall mates in my dorm freshman year that were known as Maggie and the other as Dee. One night they confessed that their legal names were Margarita and Daiquiri, respectively. In this day at this time with Heavenly and Baby Girl as legal names -- sometimes, there is a reason for a nickname.

That being said, I plugged in nicknames and the "other" variations used by our MLOs into the database when we initially registered them and as we've hired additional, I've checked to make sure the nickname was on their listing as well. If Kenneth wants his business cards to say "Chip", and introduces himself to clients as Chip -- then that needs to on the registry as an other name.