Vendor Guru Q&A - Lending

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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.

Loan Created in Signers Name-Company Debt

10/14/2018

A customer is signing for a company and owns 25% of the company, if a loan is created in the signers name would the companies debt need to be included in aggregate debt?

HMDA GIR Mixed Use Properties

10/14/2018

We made a loan to a non-profit for the purpose of acquiring and renovating 10 different properties. Loan is construction - perm. Eight of the properties are residential and the other two properties are commercial. The majority of the square footage (about 72%) of the total square footage of all ten properties is commercial. The two commercial properties are strictly commercial (not mixed use). The commercial properties comprise about 39% of the net collateral value, although the majority of the property values are lender's valuations, and not actual appraisals. I've looked through the HMDA GIR and do not see where this situation is addressed, unless I've overlooked it. The closest situation I could find addressed mixed use properties. In those situations, it stated it was at the lender's discretion, citing use of square footage or value. So I have square footage leaning to commercial (exempt) and value to residential (reportable). Would this be HMDA reportable?

Home Equity Loan: Improvement or Cash Out Refi?

10/14/2018

We are brand new to HMDA due to purchasing a branch in an MSA. We will start inputting in 2019. Our question is, if we have a home equity loan (we do not do LOC'S on home loans), it is to refinance existing mortgage and other funds are used for improvements to the property. Would that be a refi, home improvement or cash out refi?

Closed-End Threshold Test: Count Purchased Loans?

10/14/2018

Do we count purchased loans for the closed-end threshold test to determine if we are a small filer under HMDA? 1003.3(c)(4) states that the purchase of an interest in a pool of loans is an exempted transaction under HMDA, however I do not think that this includes mortgage loans purchased as a pool of loans. Thank you!

Getting Escrow Statements in Sync

10/14/2018

Doing annual statements is a real pain every month. What can we do to make these easier?

Latest Lending - SAFE Act Topics

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