Wrong Institution ID

Posted By: TMatt87

Wrong Institution ID - 07/05/11 02:25 PM

Due to a typo, our applications for the last few months were printed with the wrong institution NMLS #. Since the regulation doesn't require the institution NMLS # to be disclosed, do we need to go back and correct all the applications that had the wrong number? Any input is appreciated.
Posted By: Dani York, CRCM

Re: Wrong Institution ID - 07/05/11 03:49 PM

1--Why are you putting the bank's NMLS id number on applications? Is it for investors on your secondary market loans? The bank's number is not required to be disclosed (unless the investor is requiring it). Only the MLO is required to be disclosed by the SAFE Act.

2--Which applications have the typo? If in-house, I wouldn't worry about it since it's not required anyway. If for secondary market and the investor requires it, you may want to correct it so they don't try to make you repurchase the loans on a stupid technicality.
Posted By: TMatt87

Re: Wrong Institution ID - 07/05/11 04:08 PM

The typos are on our secondary market applications. I am unaware of any investors requiring the bank's number. To be honest, I think the only reason we added it to the applications is because there is a box for it on the 1003.

If there are no investor requirements, would you still suggest correcting the errors or, since it isn't required by anyone, just make sure it is correct going forward?

Thanks!
Posted By: Dani York, CRCM

Re: Wrong Institution ID - 07/05/11 06:33 PM

If no one is requiring it (ie investors, FNMA, FHA, etc) I wouldn't correct the errors nor would I include the info going forward. It's an extraneous piece of information at this point. Per the rule, the bank number is not required to be disclosed, so I wouldn't disclose it at all.