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Two MLOs are employed by the same financial institution and the loan will remain in-house by the FI that originated the loan.
MLO #1 takes an application and negotiates the terms and MLO #2 will have the primary responsibility for the transaction as of the date of action taken (such as the loan will be booked under MLO #2 number as the primary loan officer), you should report MLO #2 as the NMLS # for reporting purposes. Is this correct?
I agree, you would report the NMLS# of the primary MLO as of the date of action taken.
The HMDA Getting it Right guide states:
If more than one individual associated with a Covered Loan or Application meets the definition of “mortgage loan originator,” as defined in Regulation G or Regulation H, a Financial Institution reports the NMLSR ID of the individual mortgage loan originator with primary responsibility for the transaction as of the date of action taken. A Financial Institution that establishes and follows a reasonable, written policy for determining which individual mortgage loan originator has primary responsibility for the reported transaction as of the date of action taken complies with this reporting requirement. Comment 4(a)(34)-3.
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