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#2198204 - 11/14/18 06:31 PM NMLS# for Online Applications
Brightside3277 Offline
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Joined: Aug 2012
Posts: 88
Oklahoma
My Bank is considering starting to offer online applications for TRID related loans. I know that the NMLS# is required on the application, TRID disclosures, Promissory Note and Security Agreement. How are other Bank's handling this for their online applications when an officer is not known at the time?
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S.A.F.E. Act Forum
#2198248 - 11/14/18 09:20 PM Re: NMLS# for Online Applications Brightside3277
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
The application FORM is not an application. The application form, completed by the applicant, is an application. You don't need any NMLS number on the blank form; you assign a NMLS number to it once it's received.
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#2201035 - 12/18/18 08:26 PM Re: NMLS# for Online Applications Brightside3277
river girl Offline
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Joined: Nov 2004
Posts: 1,005
Our online applications go to a lender in our call center. I have been reading through the SAFE Act today and can't see whether we have to provide a NMLS number on an incomplete application.
Can we say the 6 pieces needed for RESPA are also needed to provide a NMLS number?

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#2201043 - 12/18/18 08:45 PM Re: NMLS# for Online Applications Brightside3277
Adam Witmer Offline
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Joined: Sep 2010
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You can find the requirements to have the NMLS number on the application in 1026.36(g) of Regulation Z.
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All statements are my opinion, not those of my employer, and should not be taken as legal advice.
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#2201046 - 12/18/18 08:50 PM Re: NMLS# for Online Applications Brightside3277
rlcarey Online
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rlcarey
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Galveston, TX
You have to provide the officer's NMLS# on the initial written communication to the customer and it would have to be on the application retained by the bank.
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#2201051 - 12/18/18 09:05 PM Re: NMLS# for Online Applications rlcarey
river girl Offline
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but the application is online and no loan officer has had any communication at all before the consumer fills out the entire application and hits submit. Then it goes into a queue that is assigned to call center lenders. At that time, the first communication whether a phone call or an email does contain that particular lenders NMLS number. Are you saying I need to provide just one of the lenders NMLS on the online application even thought it might not get assigned to them?

For other online applications received without enough information to make a decision or we try and reach out but never get ahold of anyone, we send an incomplete letter or AAN with reason of incomplete application. Does those need a NMLS # because it is the initial communication?

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#2201052 - 12/18/18 09:15 PM Re: NMLS# for Online Applications Brightside3277
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,219
Galveston, TX
If the application is not ever provided back to the applicant, then technically it would not require the NMLS #s. However, an adverse action notice or notice of incompleteness could be the first written communication in some instance.
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