Are any of you reporting your officers NMLSR ID even if you are not required to? Like on business loans or loans not secured by a dwelling? All of our officers have an NMLSR ID and I figured it would be easier to go ahead and just report their #'s on all HMDA reportable transactions.

I am working off of 1003.4(a)(34)-2 when it says, "However, some mortgage loan originators may have obtained an NMLSR ID even if they are not required to obtain one for that particular transaction. If a mortgage loan originator has been assigned an NMLSR ID, a financial institution complies with 1003.4(a)(34) by reporting the mortgage loan originator's NMLSR ID regardless of whether the mortgage loan originator is required to obtain an NMLSR ID for the particular transaction being reported by the financial institution."

My interpretation is that it isn't an option if they have an NMLSR ID. If they have an NMLSR ID (even if for a commercial purpose transaction) then it must be reported. If a commercial lender does not have one they are not required to obtain one solely for HMDA, but in your example if they already have one then you must report the ID on all of that lenders loans on the LAR regardless of consumer or business purpose.

Agree.