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Does Illinois law require us to include an NMLS number on our residential mortgage loan advertisements? – IBA Compliance Connection

Does Illinois law require us to include an NMLS number on our residential mortgage loan advertisements?

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No, Illinois law does not require banks to include NMLS numbers in residential mortgage loan advertisements.

The Illinois Residential Mortgage License Act of 1987 requires mortgage loan originators who do not work for financial institutions to display their NMLS numbers on “all residential mortgage loan application forms, solicitations, and advertisements, including business cards and websites.” However, bank employees are exempted from the law. Consequently, this requirement would not apply to your bank’s advertisements.

For resources related to our guidance, please see:

  • Illinois Residential Mortgage License Act of 1987, 205 ILCS 635/7-14 (“The unique identifier of any person originating a residential mortgage loan shall be clearly shown on all residential mortgage loan application forms, solicitations, and advertisements, including business cards and websites, and any other documents as established by rule, regulation, or order of the Commissioner.”)
  • Illinois Residential Mortgage License Act of 1987, 205 ILCS 635/1-3(a) (“No provision of this Act shall apply to an exempt person or entity as defined in items (1) and (1.5) of subsection (d) of Section 1-4 of this Act.”)
  • Illinois Residential Mortgage License Act of 1987, 205 ILCS 635/1-4(d)(1.5) (“‘Exempt person or entity’ shall mean the following: (1) . . . any national bank, federally chartered savings and loan association, federal savings bank, federal credit union; . . . any bank, savings and loan association, savings bank, or credit union organized under the laws of this or any other state; . . .”)
  • Illinois Residential Mortgage License Act of 1987, 205 ILCS 635/1-4(d)(1.5) (“Any employee of a person or entity mentioned in item (1) of this subsection, when acting for such person or entity, or any registered mortgage loan originator when acting for an entity described in subsection (tt) of this Section.”)