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Pre-Application Disclosures for HELOC (NMLS#)

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Question: 
In regards to pre-application disclosures for a HELOC, does the bank's NMLS # need to be disclosed along with the banker's NMLS # or does the bank's NMLS # only need to be disclosed on the boarding/booking documents?
Answer: 

The requirements for providing the NMLSR IDs of the loan originator organization and the individual loan originator on specific loan documents are found in Regulation Z § 1026.36(g). That information is required on the credit application (once received from the consumer); the loan estimate and closing disclosure required under the TRID requirements of § 1026.19(e) and (f); the note of loan contract; and the security instrument.

Since the TRID disclosure requirements in § 1026.19(e) and (f) don't apply to HELOCs, the HELOC disclosures (pre-application or otherwise) would not have to include the NMLSR ID information.

First published on 05/21/2017

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