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Does Illinois law require us to include a mortgage loan originator’s NMLS number on the closing documents for a HELOC? We know this is not required under federal law. – IBA Compliance Connection

Does Illinois law require us to include a mortgage loan originator’s NMLS number on the closing documents for a HELOC? We know this is not required under federal law.

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No, Illinois law does not require a financial institution employee to provide a Nationwide Mortgage Licensing System and Registry (NMLSR) identifier on loan documents. The Illinois law governing the licensure of mortgage loan originators, the Residential Mortgage License Act of 1987, governs the use of NMLSR identifiers on loan documents, but it does not apply to banks or their employees.

For resources related to our guidance, please see:

  • Residential Mortgage License Act of 1987, 205 ILCS 635/1-4(d) (definition of “exempt person or entity” includes “any bank, savings and loan association, savings bank, or credit union . .. [and] any employee” of those entities)