Compliance Question of the Week

Am I required to ‘display’ the individual NMLS identifier number of our MLOs?

While the SAFE Act does not have any requirement to ‘display’ the unique identifier number of your MLOs, there are some provisions that cover the use of the NMLS identifier number.

§ 761.105   Use of unique identifier.

(a) The credit union shall make the unique identifier(s) of its registered mortgage loan originator(s) available to members in a manner and method practicable to the credit union.

(b) A registered mortgage loan originator shall provide his or her unique identifier to a member:

(1) Upon request;

(2) Before acting as a mortgage loan originator; and

(3) Through the originator’s initial written communication with a member, if any, whether on paper or electronically.

Because the regulation allows credit unions to choose the manner and method on how they make the NMLS number available to the members, some credit unions have chosen to display the number on the MLO’s business cards.  This best practice does facilitate getting number (2) out of the way, but is not a requirement of the regulation.

In addition, certain Federal Home Loan Agencies (Freddie and Fannie) require the use of the NMLS number on their applications.  The applications have special boxes to put the number in.

Questions? Contact the Compliance Hotline: 1.800.546.4465 or e-mail us at compliance@nwcua.org

Posted in Compliance.