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Consumer Lender's NMLS# on Blank App?

Question: 
Does a consumer lender's NMLS number have to be on a blank application if it is being given to a customer and no other information is collected or given out?
Answer: 

by Dan Persfull:

No. However, if the MLO is providing the application I would have to assume they are/were acting as an originator and they would have to provide the consumer their NMLS#, but it does not have to be on the blank application. Our MLOs provide their business cards in the loan packet provided to the consumer.

Answer: 

by Randy Carey:

(g) Name and NMLSR ID on loan documents. (1) For a consumer credit transaction secured by a dwelling, a loan originator organization must include on the loan documents described in paragraph (g)(2) of this section, whenever each such loan document is provided to a consumer or presented to a consumer for signature

Answer: 

by Dan Persfull:

Official Interpretation

36(g) Name and NMLSR ID on Loan Documents

Paragraph 36(g)(1)

1. NMLSR ID. Section 1026.36(g) requires a loan originator organization to include its name and NMLSR ID and the name and NMLSR ID of the individual loan originator on certain loan documents. As provided in § 1026.36(a)(1), the term "loan originator" includes creditors that engage in loan originator activities for purposes of this requirement. Thus, for example, if an individual loan originator employed by a bank originates a loan, the names and NMLSR IDs of the individual and the bank must be included on covered loan documents. The NMLSR ID is a number generally assigned by the NMLSR to individuals registered or licensed through NMLSR to provide loan origination services. For more information, see the SAFE Act sections 1503(3) and (12) and 1504 (12 U.S.C. 5102(3) and (12) and 5103), and its implementing regulations (12 CFR 1007.103(a) and 1008.103(a)(2)). A loan originator organization may also have an NMLSR unique identifier.

I would contend if no loan is originated then a blank application is not a covered loan document.

Answer: 

by John Burnett:

I'd say that an application handed to a consumer for the consumer's signature is a covered document, but that typically happens sometime around closing. The blank application form isn't an application at all, in my opinion, unless the consumer uses it to submit an application. At that point, it's an application, and it should have the NMLS# added.

First published on 04/14/2019

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