Does the loan originator have to provide the identifier when taking a phone app? (it seems that they would, I just can't find it mentioned in the Act)

The rule states that the MLO must give their unique identifier before acting as an MLO. The rule does not differentiate between how the MLO takes the application. If your MLO is accepting the application over the phone and during the same phone call offering or negotiating terms, then they need to disclose thier unique identifier before acting as an MLO. Basically either disclose at the beginning of the call or immediately before talking rates, other terms, etc.

Or just don't take apps by phone.

Is anybody developing a telephone script for the MLO's to use? Otherwise, if the MLOs even remember to give it, I forsee them quickly throwing in "...oh, by the way, my NMLS# is ....." Is that acceptable?

I think however they give it in that instance is acceptable. We aren't scripting anything, just establishing the procedures for when to give the NMLS# out.

I am new to the forum. We have scripted instructions for our MLO's for face-to-face and telephone applications: "Federal regulations require me to inform you that my Mortgage Loan Originator number is xxxxxx."

Thanks folks. The number will also be included on any written correspondence and the application just incase the applicant misses it during the phone conversation, but was curious to see what others are doing.

If the applicant misses it, it really won't matter as the average consumre will have no idea what the number is for nor will they know to do with it, nor will they care.

You still want to address it for exams and the like though.

What about those "rate shoppers" calling and asking for our 30 year mortgage rates? Tellers can read a rate sheet and provide these, yet aren't registered MLOs.

They aren't considered MLOs in this instance because they haven't accepted an application. It's a 2-prong test. That being said, our bank doesn't allow the tellers to quote rates. All rate inquiries are referred to a loan officer (all of which are registered MLOs).