Skip to content
BOL Conferences Top Gun 23
Thread Options
#2210477 - 04/05/19 04:20 PM Inactive NMLSR ID
LoveHMDA Offline
Gold Star
Joined: Nov 2005
Posts: 277
We have a Commercial Lender that was once a Mortgage Lender with another FI. She has a NMLSR ID that is currently not active. Would we still need to report her inactive NMLSR ID for her commercial HMDA reportable deals?

Return to Top
HMDA

   
HMDA Academy
#2210483 - 04/05/19 04:40 PM Re: Inactive NMLSR ID LoveHMDA
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 80,341
Galveston, TX
If their NMLS registration is inactive, they have no NMLS number.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2210497 - 04/05/19 06:13 PM Re: Inactive NMLSR ID LoveHMDA
GTS333 Offline
Gold Star
Joined: Jun 2010
Posts: 256
Interesting question. I haven't researched the issue, and while I think rlcarey's comment make sense, I could also see an argument that you would report it.

I believe that the NMLSR has a technical "inactive" status that you can be put into for not paying fees etc. When you pay your fees, your ID is reinstated or activated, using the same number. Similarly, if you were a lawyer, your state bar licenses number is unique to you, whether its active or not. In that case, so I could see any argument that reporting it in that case is still valid (especially knowing the CFPB is keen to have as much data about a transaction as possible).

With that said, I suspect if you just pick one approach and stick with it you'll be find during an exam.
_________________________
My opinion, take it for what its worth. Opinions expressed are my own and not those of my employer and are not legal advice.

Return to Top
#2210498 - 04/05/19 06:34 PM Re: Inactive NMLSR ID LoveHMDA
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 80,341
Galveston, TX
Well, I shot from the hip and failed to pull the revolver out of the holster. My foot hurts.

An NMLSR ID for the mortgage loan originator is not required by ยง 1003.4(a)(34) to be reported by a financial institution if the mortgage loan originator is not required to obtain and has not been assigned an NMLSR ID.

Since one has been assigned, even if not active, I think you have to report.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2210622 - 04/08/19 08:58 PM Re: Inactive NMLSR ID LoveHMDA
LoveHMDA Offline
Gold Star
Joined: Nov 2005
Posts: 277
Thank you Randy and GTS333, I appreciate y'alls help!

Return to Top