Having a little discussion regarding this:

Covered institutions are required to make the unique identifiers of their registered MLOs available to consumers in a way practicable to the institution. The supplementary information to the 2010 final rule provides some guidance on how to comply with this requirement. For example, an institution could:
(1) Direct consumers to a listing of registered mortgage loan originators and their unique identifiers posted on the institution’s website;
(2) Post this information prominently in a publicly accessible place, such as a branch office lobby or the reception area of a lending office; and
(3) Establish a process to ensure that institution personnel provide the unique identifier of a registered mortgage loan originator to consumers who request it from employees other than the mortgage loan originator.

For #1, the list is available if a customer selects "Apply Now" and begins an application. I do not believe this meets the intent of #1 as the list is not viewable unless someone begins an application.

This is a good question. I don't think you are going to find a black and white answer on this as the three options listed are examples and not a hard requirement. While this requirement is provided in the "Laws and Regulation" section of the CFPB exam procedures, the actual review procedures don't include much (if any) info on what examiners should look for. My point being this: I've not heard of this being an issue in an exam, so the risk is probably fairly low as it would come down to whether your procedure is "practicable". I agree that you could adjust your procedure (for #1) to make it even less risk, but I also don't know what other ways you may be complying with the requirement (such as items 2 or 3).

Not sure if that helps, but again, this isn't black and white and is probably more of a question of your risk tolerance.

I did some testing on our website after I posted this. Not only do you have to click on "Apply Now," but when you get to the next page, you must click "Accept" and then you get the speed bump warning that you are leaving the Bank's website. It takes the person to the Consumer Connect website which has our branding.

Found some other sites that have the information on their actual website. Seems like this is what we need to do.