Notice: Function _load_textdomain_just_in_time was called incorrectly. Translation loading for the wp-migrate-db domain was triggered too early. This is usually an indicator for some code in the plugin or theme running too early. Translations should be loaded at the init action or later. Please see Debugging in WordPress for more information. (This message was added in version 6.7.0.) in /srv/app/gotoiba-dev/htdocs/web/wp-includes/functions.php on line 6121
Do we need to provide the bank’s NMLS number to our customers on any written communications? Our current procedures cover only the use of a loan originator’s NMLS number. – IBA Compliance Connection

IBA Compliance Connection

Your go to source for compliance!

Do we need to provide the bank’s NMLS number to our customers on any written communications? Our current procedures cover only the use of a loan originator’s NMLS number.

—

by

Regulation Z requires the disclosure of NMLS identifiers for both financial institutions and loan originators on credit applications, Loan Estimate and Closing Disclosures, notes and loan contracts, and security instruments.

Notably, the SAFE Act’s provisions regarding NMLS identifiers apply only to mortgage loan originators, not to financial institutions.

For resources related to our guidance, please see:

  • Regulation Z, 12 CFR 1026.36(g) (“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 . . . (i) Its name and NMLSR ID . . . .”)
  • Official Interpretations, Regulation Z, 12 CFR 1026, Paragraph 36(g)(1), Comment 1 (“As provided in § 1026.36(a)(1), the term ‘loan originator’ includes creditors that engage in loan originator activities for purposes of this requirement. Thus, for example, if an individual loan originator employed by a bank originates a loan, the names and NMLSR IDs of the individual and the bank must be included on covered loan documents.”)
  • SAFE Act regulations, 12 CFR 1007.105 (“The covered financial institution shall make the unique identifier(s) of its registered mortgage loan originator(s) available to consumers in a manner and method practicable to the institution. . . .”)