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#1961648 - 09/12/14 06:05 PM NMSR ID on the Security Instrument
noelekal Offline
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Joined: Aug 2013
Posts: 116
Texas
http://www.consumerfinance.gov/eregulati...-30108_20140118

It was pointed out on a recent compliance exam that the bank had failed to have the NMLSR ID on a security instrument.

"Informal" discussion with the examiners during that week revealed that both the MLO and the bank's MLO number is required to be placed on the security instrument, the note, and the application for all 1-4 family loans.

It now appears that everyone in the organization isn't completely on board with this. How are y'all understanding this topic?

Discussion of this topic with my immediate boss, who is on board with adding the numbers as necessary, also revealed that he feels that loan officers' correspondence, emails, business cards etc. should feature the appropriate MLO numbers but this has met with resistance in the past. I haven't found anything in the regs or on BankersOnline that addresses these aspects of loan officer correspondence.

We weren't tagged for not supplying the numbers on correspondence. No mention was made of the need for it by examiners.
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Loan Originator Compensation Rule
#1961695 - 09/12/14 07:11 PM Re: NMSR ID on the Security Instrument noelekal
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
It has to be included in the first written correspondence with a loan applicant.
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#1961894 - 09/15/14 01:01 PM Re: NMSR ID on the Security Instrument noelekal
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Two separate rules. The SAFE Act regulation (CFPB Regulation G) requirement applies to mortgage loan originators as defined under that regulation, and is found in section 1007.105. The Regulation Z requirement applies to loan originators as defined in section 1026.36(a)(1), and is found in section 1026.36(g).
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John S. Burnett
BankersOnline.com
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