Hello all - Am I interpreting this correctly? We will include the name and NMLS ID # for those LOs that are registered per the SAFE Act on all requisite docs. But we will include the name only for those LOs that do not meet the definition of MLO and do not have a NMLS ID? Thanks

Yes, that is my understanding also.


If the consumer credit transaction is secured by a dwelling, the creditor must include on the credit application, note or contract and the security instrument the loan originator (LO) name and if the LO has a NMLSR ID the ID number and the name of the LO as it appears on the NMLSR.

Is anyone else having dificulties with providing a Name and NMLS ID on an application?

Many of our covered loan programs have preprinted applications and LOs are assigned after the application is completed and returned to us.

Any suggestions on providing the info in these situations would be greatly appreciated.

I don't understand your question. The number does not have to be on an application when you hand a blank one to a customer???

When does it need to be provided on an application?

I wonder this too. On our in-house loans, we do not have a final application.

The NMLS ID# will be added to the application, when it is received in the bank or through other normal channels, i.e. website, mail, etc.
When you hand off the application to your LOs they would then add their NMLSR ID#. LOs are required to provide ID# at first contact.

We are having an issue with Laserpro. The NMLSR ID# is not on the note and they are saying that it is not required. Am I missing something? I gave our Laserpro coordinator the regulation number 1026.36(g)(1).

In the past we were providing business cards when an MLO was assigned. If I understand what you are saying, now we need to provide a copy of the application, with the NMLS ID# added?

So does our bank only have to include these numbers if the Bank is acting as a "Loan Originator Organization?"

"a loan originator organization must include on the loan documents described in paragraph (g)(2) of this section"

A business card is not a recognized application document. If you provide a blank application there is no need for a ID# on it, until it is completed and returned to the bank. When the LO acknowledges it in writing to the applicant, the NMLSR ID# should be provided. The Bank's NMLSR ID# and the LO's NMLSR# with signature would be added to application.
If your institution accepts application through its website, the LO's NMLSR ID#, Name, and the institutions NMLSR ID# would be part of response to the applicant.

If I understand what you are saying, now we need to provide a copy of the application, with the NMLS ID# added?

No, that is not what anyone is saying. You have to place the NMLS# on the application. There is no requirement to provide the application with the number back to the applicant. It is basically for the use of the regulators when they decide to prosecute a MLO and they want to know all the loans that the MLO touched.

The Bank's NMLSR ID# and the LO's NMLSR# with signature would be added to application.

Show me where a signature is required.

There is no requirement to provide the application with the number back to the applicant.

My confusion with this statement stems from the bold phrase in the regulation below.

1026.36(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, as applicable:

Well, if you choose to present an application back to the applicant for signature. Typically, an application is signed by the applicant prior to them presenting it to the bank. There is no such regulatory requirement to do so. Some bank's do retype applications for signature for secondary market purposes.

Thanks Randy!

Just to recap,

If an MLO is assigned prior to, or assists in the completion of an application their NMLS ID# must be included on the credit application.

If a consumer fills out a blank application (no MLO assigned) there is no need to provide the customer with an individual NMLS ID# on the credit application.

Skittles, we've tested our LaserPro docs and haven't had any issues. The lines were added as part of the last LaserPro release. Only thing I can suggest is to make sure you are using an application date after January 10.

Thanks Carolina. What bothers me is that LaserPro said yesterday it wasn't a requirement and would not print on the HELOC agreement. We use a Credit Agreement for our HELOC note.

The identification requirement does not apply to HELOCs.

Would this requirement also apply to temporary construction loans? We always include the NMLS name and ID on the application, but not the note or security agreement.

Take a look at 1026.36(g), it lays out the requirements.

I know this is a somewhat dated thread but I agree with the statement made by Comped earlier this year. My bank has our 1003 and consumer loan mortgage application form on our website. An applicant can't file an application electronically but is requested to print the application and bring to a bank office. 1026.36 would seem to indicate the NMLSR ID # for both the bank and MLO should be on the application on the website. Do most bank's follow that methodology or use the methodology suggested by Randy and input the NMLSR # after the application is completed by the applicant at home and then dropped off at a branch office?


1026.36(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, as applicable: