Vendor Guru Q&A - Lending

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Latest Lending - SAFE Act Topics

E-SIGN and paper

03/31/2019

If we are still delivering disclosures and statements in paper form, do we have to be concerned with E-SIGN or UETA?

Is the NMLS# Required on HELOC Notes?

10/28/2018

Is the NMLS# required on HELOC notes?

Display NMLS ID# Along with MLO ID#?

03/05/2017

Does a Company's NMLS ID number need to be displayed along with the MLO ID number?

NMLS # Required on GFE? (SAFE ACT/Reg Z)

02/12/2017

I'm the internal auditor and reviewing compliance with SAFE Act and Reg Z for including unique identifier on loan documents. We originate our reverse mortgages through two investors. The documents are produced through the investor website. Does the NMLS # have to be on the GFE? I'm not seeing it on the GFE for either of our investors. What disclosure documents exactly is it required? (they have on the note, mortgage, application)

MLO Identifier on Business Card - SAFE Act

11/22/2015

Do I need to have my MLO Registration number on any business card I might have for the bank under the SAFE Act?

NMLS# Required on Signs for Loan Originators?

04/13/2015

I am going to have signs made for our loan originators that say Financing Provided By - our bank and their contact info - do I need to include the NMLS# on these signs?

Recent Revisions of Reg Z

04/06/2015

Two questions related to the recent revisions to Reg Z. 1) Does a business purpose loan partially secured by residential RE now fall under Reg Z? Do you need to have a NMLS license to discuss RE secured products with customers, including abundance of caution liens.

New Amendment Regulations for SAFE ACT

08/25/2014

What are the new amendment regulations for the SAFE ACT going forward?

SAFE Act: MLOs Initial Written Communication

12/17/2012

This question is in regards to the SAFE Act and disclosure of the MLO's unique identifier with the initial written communication. If loan is made to an employee of Sr. Management and the MLO is Sr. Management as well, does the requirement still apply? Obviously these employees know each other well, and since the unique identifier is a tool for customers to get info about the MLO would the disclosure of the unique identifier be relevant in this case? Would an examiner cite an Institution for not having disclosed the unique identifier on initial written communication?

MLO's NMLS #s on App? CFPB Safe Act Guide

10/01/2012

Regarding SAFE Act compliance - the "Relation to Other Laws" section on page 9 of the March 2012 CFPB Safe Act guide - seems clear the MLO's NMLS number must be included on the loan application. BUT - if the loan is going to be kept in-house and not sold to the secondary market - is it still necessary to include the MLO's NMLS number on the loan application?

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Land Trust Department & Retail Banking Documents

12/08/2019

Are there any regulations concerning a Land Trust Department having access to retail banking documents in an institution?

Monthly Report on New Loans Documentation

12/08/2019

During a review of new loans for the previous month, I found that a joint credit report (husband/wife) was pulled for a new loan that was made to just 1 of them (the wife). The previous loan was a joint loan and a joint credit report was used then How do I need to document this finding in my monthly reports? Along with some additional training for the loan officer, what other things should I be aware of and keep in mind?

Opening Acct. for Campaign Fund- Use SSN?

12/08/2019

In the state of Texas, when opening an account for a campaign fund, are we required to have a TIN or can we use a SSN?

Equal Housing Lender Logo on Business Card?

12/08/2019

Does a mortgage lender's business card require an Equal Housing Lender logo?

Deed of Trust Construction Materials/Flood

12/08/2019

We have an interim construction loan that the real estate is in flood zone AE. Our Deed of Trust lists the real estate and the construction materials including drapes. All of the construction materials listed are covered under the buildings flood insurance, however the drapes are not. The plans and specs for the construction does not list drapes. Do we have to require contents coverage just to cover the drapes since it is listed in the Deed of Trust?

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