Need help. Lender is wanting to refinance his customer from the bank the lender just came from. The loans are commercial purchase to refinance secured by residential real estate. Can the lender move forward with the transfer if the NMLS transfer isn't conmpleted? Our HMDA worksheet form is asking for this number, which raised the question. TIA

The loan officer does not need a NMLS to process business purpose loans.

As for the HMDA form I would complete it with their NMLS since the transfer will be complete before the data has to be reported.

Commercial transactions do not require an NMLS registration.

Just be real careful with this, if he may have brought a customer list or any other documents or information with him from his past employer. If the other bank figures this out and files a SAR, he most likely will be banned from banking for life (if you have read any of the recent enforcement actions by the regulators). Hiring officers and then allowing them to steal old clients - well the regulators take a very dim view on that and this should have been fully explained to him.

If his old customer just happened to walk in the door without solicitation, well that better be well documented.

Thanks everyone. Randy - sending you an PM