From what you have told us, it sounds like your software vendor needs to clarify how to use its system to ensure that your mortgage loan originators (MLOs) are correctly displaying their unique identifiers (as required under 12 CFR 1007.105 and 12 CFR 1026.36(g) [effective January 10, 2014]). We recommend contacting your software vendor to ask (1) where you should enter a state-registered MLO’s unique identifier and (2) whether that unique identifier will be displayed on all loan documents (as required under 12 CFR 1026.36(g) [effective January 10, 2014]).

The federal Secure and Fair Enforcement for Mortgage Licensing Act (SAFE Act) requires states to set up mortgage licensing programs, but it doesn’t require states to license bank employees. Instead, it allows bank employees to register with the Nationwide Mortgage Licensing System (NMLS). 12 CFR 1008.103(e)(5). Illinois law exempts state-chartered banks (and other financial institutions) and their employees from the requirement to obtain a residential mortgage license. 205 ILCS 635/1-4(d).

However, nothing in the SAFE Act would prevent a state law from requiring a bank employee to obtain a state license before originating loans in that state. While we are not aware of any states that require MLO licenses from bank employees, we would recommend checking a state’s law before originating loans in that state. The NMLS has set up a very useful webpage with a United States map. For each state, it summarizes the state’s MLO licensing and provides phone numbers for the state’s licensing authority.