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Documents that Require MLO's Unique Identifier

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Question: 
We are receiving conflicting information on what documents the MLO's unique identifier has to be on. We have it on our applications but are being told that it needs to be on all correspondence, i.e., GFE, TIL, business cards as well as added to the MLO's email signature. Can you give us some guidance on this?
Answer: 

The law does not require that the number be on any specific document. This is what is says, "The bank shall make the unique identifier(s) of its registered mortgage loan originator(s) available to consumers in a manner and method practicable to the institution." It goes on to say "A registered mortgage loan originator shall provide his or her unique identifier to a consumer:
(1) Upon request;
(2) Before acting as a mortgage loan originator; and
(3) Through the originator's initial written communication with a consumer, if any, whether on paper or electronically."
It is up to the bank to decide which documents to disclose the number properly.

First published on BankersOnline.com 11/28/11

First published on 11/28/2011

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