While having a conversation with one of our areas that originate HMDA reportable loans, it came up that their practice was to report the NMLSR ID of the Underwriter/LO that actually made the decision. There have been some scenarios based on schedule or the availability to communicate where the UW/LO who's NMLSR ID showed up on Initial Disclosures/URLA was not the one reported, because they weren't there to make the actual decision (Approved, Denied, Withdrawn, etc). Normally, the same UW/LO takes the application from start to finish, so the circumstances described are not the norm for us. Once again, their practice is to report the NMLSR ID of whoever made the decision, regardless of whether who started the application/disclosure process (another UW/LO) when the original UW/LO is not available. Is this one of those things that is standard, acceptable based on consistency and the banks documented procedures, or is it incorrect? I thank everyone ahead of time for your feedback.

If more than one individual associated with a Covered Loan or Application meets the definition
of “mortgage loan originator,” as defined in Regulation G or Regulation H, a Financial
Institution reports the NMLSR ID of the individual mortgage loan originator with primary
responsibility for the transaction as of the date of action taken. A Financial Institution that
establishes and follows a reasonable, written policy for determining which individual mortgage
loan originator has primary responsibility for the reported transaction as of the date of action
taken complies with this reporting requirement. Comment 4(a)(34)-3.

I just hope that if your underwriters are primary responsible for these loans, that you are not paying your frontline MLOs lender compensation even though they are likely the ones that mainly communicate with the customer and might even attend closings.