I have a discussion with re. to a bank officer who signed page 3 of the 1003 and putting the NMLS ID which was not effective until after 2 months of his hire.

The application was taken via internet by a previous loan officer who is no longer with the company. The new manager signed it 2 months after he was hired and I explained to him that he cannot do that since, he was not an employee of the bank and his NMLS ID was not yet in place. He thinks it is ok provided there is a memo stating that he is signing in place of the previous LO. I flatly said NO because we are not in compliance. Am I right?

Having the NMLS # on a 1003 isn't a "compliance" issue at this point, at least the way i understand it. The requirements to have it on a 1003 are coming from Fannie and Freddie as a purchase requirement. If he is the acting LO for the loan and this 1003 is acting as the final application, personally, i wouldn't see a problem with it. I don't necessarily see any reason though for him to retroactively sign the initial application in the departed LO's place; instead, i'd just document the file mentioning the change in LO. Perhaps others will have a different idea.

I agree with raitchjay that in my opinion he wouldn't need to sighn the initial application. I would document about the change in LO and if the new LO needed to send anythign out to the customer (letter, etc) I would include the new NMLS number on that.

Thanks for the info.