Someone recently mentioned to me that they worked at a bank which required their MLOs to state their NMLS # every time they answered the phone.

I realize that the unique identifier has to be included before they act as a mortgage loan originator. Our MLOs include their number on all correspondence and would state their number (before taking the application) if the borrower chooses to apply for a loan over the phone. I believed that this is sufficient but now I'm doubting myself.

Different institutions, different decisions on risk and interpretations of what needs to be done. Some mandate every phone call starts with it so they can ensure it's being given out, some don't worry that much.

I agree with Matt and would add: I think having them state it every time they answer the phone is overkill (and since the average person isn't going to know what an "NMLS number" is, it's going to sound weird too). I think it's much more in the spirit of the regulation when the conversation begins to head toward application territory if the LO stops and says "before we begin down this road, i'm required to tell you my NMLS #, which is simply a number that identifies me through a national registry for mortgage loan originators...." etc., etc. Just my two cents.

LO: Hello, this is Joe Loan Officer and my NMLS# is xxxxxxx

Son: Dad? Are you coming to my baseball game tonight?


Overkill? - I would say slightly.

According to the reg, a registered MLO shall prodive 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,
if any, whether or paper or electronically.

Point two may fall under verbal, but I don't believe it is when the MLO answers the phone. Now, if the person calling is asking for a mortgage loan, then, maybe it should be given verbally when the caller begins asking questions about a mortgage loan.

I agree, it's overkill as in Randy's example above.