Skip to content
BOL Conferences
Thread Options Tools
#1945283 - 07/24/14 04:56 PM Brokers and NMLS ID
SamP Offline
Member
Joined: Dec 2012
Posts: 97
Initial Application taken by a Broker contains their individual NMLS ID, as well as their respective Brokerage NMLS corporate ID on the credit application. Our institution receives the application from the Broker, which our institution will originate/fund the loan, which will be closed in our institution’s name.

Final application (as part of the settlement package) still contains the broker and their institution’s ID; However, the security instrument and note now contain the broker’s name and ID, as well as OUR institution name and NMLSID. The Broker’s company’s respective NMLS ID is not mentioned on the note or DOT.

I can't seem to locate much information on Brokers in 1026.36 (g). Does anyone take issue with how we are disclosing the Broker's NMLS ID and our Institutoin's NMLS ID on the Note and DOT?
Last edited by SamP; 07/24/14 04:57 PM.
Return to Top
General Discussion
#1945560 - 07/24/14 09:17 PM Re: Brokers and NMLS ID SamP
BTJ Offline
Member
Joined: Sep 2007
Posts: 83
From the LO Compensation CFPB Manual:

If there is more than one loan originator for a transaction, you must include the name and NMLSR ID of the individual loan originator with primary responsibility for the transaction at the time the loan document is issued. (Comment 36(g)(1)(ii)-1)
You have flexibility to establish a reasonable, written policy that sets forth how you will determine which individual loan originator has primary responsibility for a transaction.
If you establish such a policy, follow it for each transaction, and document your actions, you will comply with this requirement.

Return to Top