I know this has to have been addressed here before but forgive me because I simply can't come up with the combination of words that will successfully search for it. When you have one MLO take the application and work with the borrower who leaves the company before the loan closes and a new MLO is assigned to the file, which MLO's name should be on the CD, the original MLO or the one who takes the file over prior to closing? If it's close to closing the borrower may not even have any interaction with the new MLO and the new one didn't take any documents, enter any data or ask any of the questions. Thanks!

Check out the SAFE Act forum: https://www.bankersonline.com/forum...ng-a-week-after-mlo-resigns#Post2215227.

The short answer is that the MLO responsible for the loan at the time you issue the CD is who you should list. In this case, that is the new LO. The long answer is found in comment 1 to Paragraph 36(g)(1)(ii) of Regulation Z:

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.

When the LO changes on a file, we make the change as soon as that happens and the new LO would show up on not only the CD, but if there are any subsequent LEs before then.

So you would update the LO as soon as that happens. You might want to make sure both LOs had valid NMLS licenses when the application was taken.