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#1533012 - 04/07/11 08:36 PM
Re: Providing NMLS ID #
Queen Mum
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Power Poster
Joined: Apr 2005
Posts: 3,663
TN
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Technically, I think they should be giving out their numbers as soon as they are registered and show active. Practically, I don't think giving them out now makes a lot of sense since the consumer can't go out and look the MLOs up on the consumer site until after July 29th.
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I can't herd the cats anymore, so I just set up the electric fences and let them fry when they stray out of bounds.
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#1536932 - 04/18/11 06:30 PM
Re: Providing NMLS ID #
Dani York, CRCM
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100 Club
Joined: Feb 2008
Posts: 142
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Does anyone have a sample lobby notice they would be willing to share? I know the lobby notice is not required and is just an example of making unique identifiers of MLOs available to consumers....but I would sure like to see what others are listing on a lobby notice.
Thanks!!
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#1536944 - 04/18/11 06:39 PM
Re: Providing NMLS ID #
Valley Girl
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Power Poster
Joined: Apr 2005
Posts: 3,663
TN
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If I was to do a lobby notice, I would just list the MLO names and NMLS ID numbers in columns. The title would probably be <Bank Name> Mortgage Loan Originators. I would include in mouseprint at the bottom a footnote that consumers may lookup our MLOs by their NMLS ID # at <NMLS consumer access website address>.
_________________________
I can't herd the cats anymore, so I just set up the electric fences and let them fry when they stray out of bounds.
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#1537204 - 04/19/11 01:03 PM
Re: Providing NMLS ID #
Valley Girl
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100 Club
Joined: Feb 2008
Posts: 142
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One more question.......I'm assuming that if you have multiple locations in different markets that your listing on your website or in your lobby would include all MLOs and not just the MLOs in that market?
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#1537210 - 04/19/11 01:13 PM
Re: Providing NMLS ID #
Valley Girl
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Power Poster
Joined: Apr 2005
Posts: 3,663
TN
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If you are going to do a lobby notice or a web listing, it would be easier to maintain the postings if you just put everyone on one. If you do it by market areas, you will have multiple lists to manage, and more places to make mistakes.
There are no hard and fast rules on what needs to be on a lobby notice or web listing. The rule just offered those options as a way to comply with providing the list to consumers.
_________________________
I can't herd the cats anymore, so I just set up the electric fences and let them fry when they stray out of bounds.
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#1537262 - 04/19/11 02:10 PM
Re: Providing NMLS ID #
Dani York, CRCM
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100 Club
Joined: Apr 2003
Posts: 122
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Is anyone including the institution's ID number along with the MLO number on the information lists or including it on business cards, etc?
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#1537386 - 04/19/11 04:00 PM
Re: Providing NMLS ID #
dwedding
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Power Poster
Joined: Apr 2005
Posts: 3,663
TN
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On the communication from the MLOs, we are only putting that MLO's number. The institution number will be on our list available by request (and maybe our website....still thinking about that one).
_________________________
I can't herd the cats anymore, so I just set up the electric fences and let them fry when they stray out of bounds.
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#1543028 - 04/28/11 08:05 PM
Re: Providing NMLS ID #
river girl
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Power Poster
Joined: Nov 2003
Posts: 3,745
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For the signs in the branches and at the lenders desk and on the website are you listing ALL of your MLOs? We have around 100 so..... I could see having each lender with their own sign at their own desk. Is that what others are doing?
For our mortgage loans, we receive numerous loans through our website and the GFE and early disclosures are all automated. They are delivered electronically before the loan is even assigned to a lender so do we have to attach a list of all MLOs with their numbers to our early packet? Hey Rivergirl - what did you decide? We are in the same boat.
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It's not that I take life for granted. It's only that the good won't make it. Innocence dies, while Villany Thrives.
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#1550059 - 05/12/11 03:14 PM
Re: Providing NMLS ID #
Tesla
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Diamond Poster
Joined: Sep 2008
Posts: 2,481
Midwest
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Do we have to inlcude teh bank number or the MLO number on the mortgage?
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#1550060 - 05/12/11 03:15 PM
Re: Providing NMLS ID #
ahkcompliance
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Power Poster
Joined: Apr 2005
Posts: 3,663
TN
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Do we have to inlcude teh bank number or the MLO number on the mortgage? Do you mean the mortgage document (ie deed)?
_________________________
I can't herd the cats anymore, so I just set up the electric fences and let them fry when they stray out of bounds.
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#1550074 - 05/12/11 03:25 PM
Re: Providing NMLS ID #
ahkcompliance
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Power Poster
Joined: Apr 2005
Posts: 3,663
TN
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I don't think so, unless perhaps an investor is requiring it. The MLO's id number is the only thing that has to be diclosed. That number is only required by the rule to be disclosed before acting as an MLO, upon request, and in the first written initial communication. The mortgage document itself doesn't qualify under any of those.
Investors and FNMA have added requirements for the bank id and MLO id to appear on other documents. If you are selling the loan to FNMA or an investor, then you will want to check on their requirements for disclosing the id number.
_________________________
I can't herd the cats anymore, so I just set up the electric fences and let them fry when they stray out of bounds.
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#1550081 - 05/12/11 03:30 PM
Re: Providing NMLS ID #
Dani York, CRCM
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Diamond Poster
Joined: Sep 2008
Posts: 2,481
Midwest
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That is what I thought but just wanted to double check with someone else.
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#1550189 - 05/12/11 04:23 PM
Re: Providing NMLS ID #
ahkcompliance
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100 Club
Joined: Nov 2004
Posts: 237
USA
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I don't know how this interplays with the regulations, but the Dodd-Frank Act does say under Section 129B (Residential mortgage loan origination):
‘‘(1) STANDARD.—Subject to regulations prescribed under this subsection, each mortgage originator shall, in addition to the duties imposed by otherwise applicable provisions of State or Federal law—
‘‘(A) be qualified and, when required, registered and licensed as a mortgage originator in accordance with applicable State or Federal law, including the Secure and Fair Enforcement for Mortgage Licensing Act of 2008; and
‘‘(B) include on all loan documents any unique identi- fier of the mortgage originator provided by the Nationwide Mortgage Licensing System and Registry."
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#1550256 - 05/12/11 05:02 PM
Re: Providing NMLS ID #
Amos
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Power Poster
Joined: Apr 2005
Posts: 3,663
TN
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I don't know how this interplays with the regulations, but the Dodd-Frank Act does say under Section 129B (Residential mortgage loan origination):
‘‘(1) STANDARD.—Subject to regulations prescribed under this subsection, each mortgage originator shall, in addition to the duties imposed by otherwise applicable provisions of State or Federal law—
‘‘(A) be qualified and, when required, registered and licensed as a mortgage originator in accordance with applicable State or Federal law, including the Secure and Fair Enforcement for Mortgage Licensing Act of 2008; and
‘‘(B) include on all loan documents any unique identi- fier of the mortgage originator provided by the Nationwide Mortgage Licensing System and Registry."
Your highlight is "subject to regulation prescribed under this subsection". The implementing regulations of the DFA have not been issued yet.
_________________________
I can't herd the cats anymore, so I just set up the electric fences and let them fry when they stray out of bounds.
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#1550258 - 05/12/11 05:02 PM
Re: Providing NMLS ID #
Queen Mum
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New Poster
Joined: Nov 2009
Posts: 16
Indiana
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Is anyone including the NMLS# on all loan documents yet?
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#1550259 - 05/12/11 05:03 PM
Re: Providing NMLS ID #
Allshouse
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Power Poster
Joined: Apr 2005
Posts: 3,663
TN
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We aren't. We are only putting it on letters, emails, and business cards. For our secondary market loans, we are putting it wherever the investor asks for it.
_________________________
I can't herd the cats anymore, so I just set up the electric fences and let them fry when they stray out of bounds.
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#1550286 - 05/12/11 05:28 PM
Re: Providing NMLS ID #
Dani York, CRCM
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New Poster
Joined: Nov 2009
Posts: 16
Indiana
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I know there has been some discussion in regards to disclosing the MLO's NMLS# in advertising or any marketing materials but is this required?
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#1550387 - 05/12/11 06:48 PM
Re: Providing NMLS ID #
Allshouse
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100 Club
Joined: Feb 2011
Posts: 128
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We have a section in our loan application that leaves room for the bank and the mlo's number. Makes it pretty simple. We are also putting it on their business cards, email messages, and name plates on their desk. I also have a notice in all of our lobbies with all the numbers and the website to view their information.
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#1550854 - 05/13/11 02:40 PM
Re: Providing NMLS ID #
sway
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Member
Joined: Aug 2008
Posts: 88
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Dumb question....but is the lobby notice a requirement? I don't remember reading or hearing that.
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#1550863 - 05/13/11 02:45 PM
Re: Providing NMLS ID #
auditgirl6
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Diamond Poster
Joined: Jul 2006
Posts: 1,115
Where the Green Grass Grows
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Not a requirement. Just a way some banks are "making their MLO's #'s available" as required by the reg. You could have it posted on the internet, a list to give out when requested. A lobby notice is NOT required.
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#1562661 - 06/09/11 01:18 PM
Re: Providing NMLS ID #
Always In Training
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100 Club
Joined: Jun 2010
Posts: 207
Chatsworh PA
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I ended up doing a flyer for each MLO with thier ID and what that means to consumers. We added to each signature line. I put a flyer with all MLO's listed on our intranet sitefor employees to hand out if requested.
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