Mortgage department would like to start branding themselves as XYZ Mortgage rather than XYZ Bank but only for marketing purposes. The logo, letterhead, email, advertising would reflect XYZ Mortgage. We are not registered with NMLS as XYZ Mortgage.

We currently are set up with an NMLS identity as XYZ Bank and all MLOs have NMLS #s under Bank. Our loan documents document Bank rather than Mortgage, so I think the MLO #s under Bank must be shown on the Loan App, Note, and Mortgage.

I have recommended XYZ Mortgage, a division of XYZ Bank, but Mortgage is insistent that they don't want "Bank" in the verbiage.

Can the MLOs NMLS #s for Bank be used in the advertisement for Mortgage? My concern is that if a consumer, or an examiner, wanted to see if Mortgage had any nefarious activity by searching the NMLS website, there would be no XYZ Mortgage registered, but that may not be anything for which to be concerned.

If Mortgage must be registered with NMLS, can the MLOs be registered under both Bank and Mortgage?

NMLS is stumped by the questions, and I'm hopeful that I've explained it well enough that I can get a good direction in which to proceed.

As far as I can tell, a bank cannot register trade names in the NMLS system like a State licensed mortgage company might be able. To register employees under a mortgage company, when you are a bank, I do not believe would be allowed, as the entity exists in name only.

As far as NMLS#s in advertising, I would just ask why you are including them?