NMLSR and other license info

The commentary to 1026.38(r)-4 requires disclosure of an NMLSR ID number for each person identified in the "contacts table."

The commentary further states that "if the creditor, mortgage broker, or natural person has an NMLSR ID and a separate license number or unique identifier issued by the applicable State, locatility, or other regulatory body with responsibility for licensing and/or registering such entity or person's business activities, both the NLSR ID and the separate license number or unique identifier is disclosed.

I'm perplexed as to what additional license info would need to be obtained from Realtors, settlement agents, Loan Originators. How do we ask for this -- what exactly are we asking for? These entities may have a variety of licenses some of which have nothing to do with mortgage transactions. For example, would a bank need to disclose the bank's FDIC#'s? What if the Loan Originator has a license to sell investments (unlikely, and questionable, I know).

I'm just wondering how much legwork we must go through here and which types of licenses we are looking to disclose. Seems to me only those that relate to mortgage transactions. Thoughts?

Per the section by section analysis, the point here is to show that the parties to the transaction are appropriately licensed for the transaction, not anything else they do in their life.

We have lenders that do lot loans and do not have an NMLS ID. Under TRID, would we leave the Contact NMLS ID blank and only list the Bank's NMLS ID? I'm hoping management decides for all consumer purpose loans secured by real property to funnel to an MLO and then this would not be a concern.

The regulation calls for including the ID if the person has one. It does not require that the individual or entity have such an ID.

Thank you Kathleen and John for helping me find my way through this maze -- the vodka isn't helping.

Nor does tequila, I understand.

We are finding realtors listed on the contract with expired license. What is our responsibility in this case?

Curiously, how do you know? Are you checking them somehow?

Yes, Our post closing team checks on them on the state website to verify we have the correct number listed on the CD. We came to find out there were few expired.

If you were going to do something about it - a post-closing review is not the appropriate time. Why are these not checked before the CD is issued if they are readily available. You need to check your State law regarding what operating as a non-licensed realtor in your State means.