I recently had a debate with a former colleague regarding the Mortgage Loan Originator (MLO) e-signature on the initial 1003 sent to the borrower for initial disclosure purposes. This colleague stated that the MLO had given consent/permission to the processor to complete the MLO's e-signature due to the expeditious nature of the loan in question as the MLO would not be able to get to it for a few days. Keep in mind that it was only the e-signature of the MLO on the initial 1003, not the borrower.
This individual was not being fired or resigning as they would be returning within 2-3 days but the loan needed to be moved into underwriting.
I was not to sure about this. Does this constitute a violation, or is it considered fraud?
If a HMDA applicable application was withdrawn by the borrower before it ever got to the originator, what do we put for the NMLS number? Can we leave blank, should we put N/A (I believe that's only for Originators that don't have and don't need NMLS numbers), should we default to a manager or is there another recommendation?
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?
Does a Company's NMLS ID number need to be displayed along with the MLO ID number?
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)
Do I need to have my MLO Registration number on any business card I might have for the bank under the SAFE Act?
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?
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.
What are the new amendment regulations for the SAFE ACT going forward?