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#2186748 - 07/25/18 03:21 PM Terminated MLO on closing docs?
CRL Offline
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CRL
Joined: Sep 2003
Posts: 579
If we terminate a MLO who has loans in the pipeline, should we list the originating MLO/NMLSR ID# on the closing docs or the MLO who replaced the original MLO? We will compensate the terminated MLO for the loans he had in the pipeline that close.

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S.A.F.E. Act Forum
#2186760 - 07/25/18 03:58 PM Re: Terminated MLO on closing docs? CRL
JC (Darth HMDA) Offline
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JC (Darth HMDA)
Joined: Dec 2013
Posts: 1,399
CA
In cases where this happened at my previous job (when they quit, not terminated) it was the number of the LO who was assigned the file at the time of closing.
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The opinions expressed are mine, do not represent the opinions of my employer, and they are not to be taken as legal advice.

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#2186764 - 07/25/18 04:05 PM Re: Terminated MLO on closing docs? CRL
CRL Offline
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CRL
Joined: Sep 2003
Posts: 579
Thanks Darth, I think you're right. I believe I found the answer, not in the SAFE Act, but in TILA:

Paragraph 36(g)(1)(ii)
1. Multiple individual loan originators. If more than one individual meets the definition of a loan originator for a transaction, the name and NMLSR ID of the individual loan originator with primary responsibility for the transaction at the time the loan document is issued must be included. A loan originator organization that establishes and follows a reasonable, written policy for determining which individual loan originator has primary responsibility for the transaction at the time the document is issued complies with the requirement. If the individual loan originator with primary responsibility for a transaction at the time a document is issued is not the same individual loan originator who had primary responsibility for the transaction at the time that a previously issued document was issued, the previously issued document is not required to be reissued merely to change a loan originator name and NMLSR ID.
Last edited by CRL; 07/25/18 04:07 PM.
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