I am working on a self-assessment review for the SAFE Act. When reviewing our list of users, I see several "Inactive Failed to Renew" users. By researching I've found that these folks are no longer in a MLO role - but are still employed at our bank. Is this how these should be left? Should we not just remove them from the registry? I am not the NMLS administrator, so I'm unable to login to see if there are other "status" choices. Any guidance from other NMLS admins would be greatly appreciated. Thanks!

I believe they just go inactive when their current registration expires or their affiliation with the mother ship is severed.

And remember that, if they ever again return to the role of MLO, they will have to reactivate their old registration, since they don't get a new number.

Thank you so much for your responses!

We have a situation where an employee previously has a number but switched positions and their registration became inactive. A few years later she is back in a MLO position. She is awaiting reactivation. She is currently still waiting for her background check. Can she originate mortgage loans with an inactive number?

No.

When testing for compliance of a MLOs registration and renewal information, should we be requiring updates to contact information if it's "optional" such as home phone and cell phone numbers?

While those fields are optional - they either should be blank or correct. The MLO has to attest to the accuracy of all information.

That makes sense.