Does a Company's NMLS ID number need to be displayed along with the MLO ID number?
I'm the internal auditor and reviewing compliance with SAFE Act and Reg Z for including unique identifier on loan documents. We originate our reverse mortgages through two investors. The documents are produced through the investor website. Does the NMLS # have to be on the GFE? I'm not seeing it on the GFE for either of our investors. What disclosure documents exactly is it required? (they have on the note, mortgage, application)
Do I need to have my MLO Registration number on any business card I might have for the bank under the SAFE Act?
I am going to have signs made for our loan originators that say Financing Provided By - our bank and their contact info - do I need to include the NMLS# on these signs?
Two questions related to the recent revisions to Reg Z. 1) Does a business purpose loan partially secured by residential RE now fall under Reg Z? Do you need to have a NMLS license to discuss RE secured products with customers, including abundance of caution liens.
What are the new amendment regulations for the SAFE ACT going forward?
This question is in regards to the SAFE Act and disclosure of the MLO's unique identifier with the initial written communication. If loan is made to an employee of Sr. Management and the MLO is Sr. Management as well, does the requirement still apply? Obviously these employees know each other well, and since the unique identifier is a tool for customers to get info about the MLO would the disclosure of the unique identifier be relevant in this case? Would an examiner cite an Institution for not having disclosed the unique identifier on initial written communication?
Regarding SAFE Act compliance - the "Relation to Other Laws" section on page 9 of the March 2012 CFPB Safe Act guide - seems clear the MLO's NMLS number must be included on the loan application. BUT - if the loan is going to be kept in-house and not sold to the secondary market - is it still necessary to include the MLO's NMLS number on the loan application?
We have an individual requesting a business purpose loan secured by her home. Do we complete the government monitoring section of the application? We are not HMDA reportable. Also, is the loan originator section of the application required to be completed by the MLO?
Does the SAFE Act require us to conduct an annual audit? And if so, what is the Section of the Act that supports this? What does it say?