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Latest Lending - SAFE Act Topics

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?

Govt Monitor App for Business Purpose Loan?

06/11/2012

We have an individual requesting a business purpose loan secured by her home. Do we complete the government monitoring section of the application? We are not HMDA reportable. Also, is the loan originator section of the application required to be completed by the MLO?

Does the SAFE Act Require an Annual Audit?

01/16/2012

Does the SAFE Act require us to conduct an annual audit? And if so, what is the Section of the Act that supports this? What does it say?

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Policies & Training: What's Required and What's "Required"

Management is always looking for ways to reduce costs and use staff more efficiently.

Why Are We Confused?

If you are feeling confused, you are in good company. Almost anyone who deals with mortgage lending compliance is struggling with the changes. Questions are flying. We are surrounded by chaos.

Timing of rate change notices

08/12/2018

Our vendor says that we have to send a rate change notice 210 days before the first payment at the adjusted level. This can't be right. We have no idea what the adjusted rate will be that far before the adjustment date.

Procedures for Force Placing Auto Insurance

08/12/2018

What are the procedures for force placing auto insurance on a customer, who's auto policy has lapsed? I have found procedures for hazard and flood but wondering if there are different procedures for vehicles.

Home Used for Business Line of Credit-HMDA Report?

08/12/2018

Is the following scenario HMDA reportable? The borrower owns his primary residence free and clear. He is going to use this home for a business line of credit. The purpose of the business line of credit will be for him to purchase homes, repair or remodel and resell. (He is flipping them.) We will be advancing funds and depositing to his checking account and we will have no interest in the homes that he flips.

New Business Loan App for the New Borrower?

08/12/2018

I have an entity assuming the debt of another to purchase a residential property. Since the loan will be secured by a first lien on a residential dwelling, will I need a new business loan application for the new borrower? Our original business loan application specifies the original borrower.

When can we use a scan of an ID?

08/12/2018

We are offering loans via a mobile app. Can we accept scans of IDs as that is a good way to help verify we are engaged with our customer, by having them send us a picture of their ID using a smartphone.

Latest Lending - SAFE Act Topics

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