We have commercial lenders that have received their NMLS numbers in the past. We recently excluded several of them from our MLO list due to a merger with another bank and the bank name changed. We updated the records in the NMLS website and excluded them from being the new bank MLOs. HMDA says to report a NMLS number even though an applicable loan may be commercial in nature. Should we be reporting the former MLO numbers even though they are no longer on our MLO list? Or should we report their number since it still remains a part of their record in the NMLS system?

If a mortgage loan originator has been assigned an NMLSR ID, a financial institution complies with § 1003.4(a)(34) by reporting the mortgage loan originator's NMLSR ID regardless of whether the mortgage loan originator is required to obtain an NMLSR ID for the particular transaction being reported by the financial institution.

I think that is saying that if they have a number, you report regardless of active status. Just make sure none of these officers ever make a covered loan, as once you have been licensed, the de minimis rule no longer applies.

Thanks Randy!