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A question we received from a CMG member:
We have received conflicting guidance from our compliance consultants regarding the CFPB rule requiring the printing of name and license number of the loan originator and the loan originator’s organization on the 1003, note, & mortgage. We process loans originated by a broker who does not issue the initial disclosures. We get a 1003 with the broker’s name and NMLS number. We assign the application to our loan officer who will oversee the processing. When we issue the initial disclosures we do so in our name and substitute our loan officers name and NMLS number. We believe this is permitted under section 1026.36(g)(ii) as our loan originator is “… the individual loan originator with primary responsibility for the origination….” Our question is, when the note and mortgage are prepared can we use our name and that of our loan officer and his NMLS or should we use the brokers name and its loan officer’s NMLS number?
Answer by Jack Holzknecht:
If there is more than one person with responsibility for the loan, you should list the person with primary responsibility. That person can change over time. For example, at the time of application Amy may have primary responsibility, so she is listed on the application. By the time of origination Robin may have primary responsibility, so Robin is listed on the note.
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