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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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.

Home Equity Loan-Close at Home if Bedridden?

06/16/2019

On a home equity loans made in Texas, the law requires that they must close at an attorney's office, Title Co or the bank. If customer is bedridden can it close at their home?

Lender Chooses to not Read HMDA Telephone Script

06/16/2019

What happens if a lender chooses not to read the HMDA Telephone Script when required to an applicant?

RCBAP Master Policy Acceptable Form of Insurance?

06/16/2019

Is an RCBAP master policy an acceptable form of insurance for a property that is legally a planned unit development (P.U.D.) and not a condo? FEMA guidelines seem to indicate RCBAP's can only be written on condos but we are seeing insurance agents issue these on P.U.D. properties with the insured name being the HOA.

2 Separate Security Agreements-1 for Each State?

06/16/2019

If we have a customer that has their business registered with the Delaware SOS however they live in ND, do we need to produce two separate security agreements, one for each state? I noticed this changes in the governing law section of LaserPro documents.

Tolerance/Cure Amount for LE/Closing Disclosure

06/16/2019

I'm new to TRID and trying to understand tolerance and cure amounts for things such as the following: Loan Estimate : - Recording Fees $32.00 - Settlement Agent Fee $500 and - Title Search $300.00 Closing Disclosure: Title Search $500.00 What would be the tolerance cure?

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