No, we do not believe that loan originators are required to sign loan applications. Regulation Z requires the disclosure of a loan originator’s name and NMLS identifier on credit applications and other documents related to residential mortgage loans, but it does not require the loan originator’s signature. However, secondary market investors may impose their own signature requirements. For example, the Form 1003 Uniform Residential Loan Application used by Fannie Mae includes a space for the loan originator’s signature.

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 [including a credit application], whenever each such document is provided to a consumer or presented to a consumer for signature, as applicable: . . . (ii) The name of the individual loan originator (as the name appears in the NMLSR) with primary responsibility for the origination and, if the NMLSR has provided such person an NMLSR ID, that NMLSR ID.”)

• Fannie Mae, Form 1003, Uniform Residential Loan Application (rev. 6/09), page 4 (Providing a space for “Loan Originator’s Signature.”)