[AngieC]

I wanted to confirm that I am interpreting requirements of the NMLS correctly and that the NMLS # for the organization is NOT required on general advertisements. In checking the SAFE Act requirements it states the following:

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

(1) Upon request;

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

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

Editor’s Note:
For additional requirements relating to providing the unique identifier on certain mortgage-related documents, see Section 1026.36(g) of the CFPB’s Regulation Z.

The commentary to 1026.36(g) states:

36(g) Name and NMLSR ID on Loan Documents
Paragraph 36(g)(1)
1. NMLSR ID. Section 1026.36(g) requires a loan originator organization to include its name and NMLSR ID and the name and NMLSR ID of the individual loan originator on certain loan documents. As provided in § 1026.36(a)(1), the term “loan originator” includes creditors that engage in loan originator activities for purposes of this requirement. Thus, for example, if an individual loan originator employed by a bank originates a loan, the names and NMLSR IDs of the individual and the bank must be included on covered loan documents. The NMLSR ID is a number generally assigned by the NMLSR to individuals registered or licensed through NMLSR to provide loan origination services. For more information, see the SAFE Act sections 1503(3) and (12) and 1504 (12 U.S.C. 5102(3) and (12) and 5103), and its implementing regulations (12 CFR 1007.103(a) and 1008.103(a)(2)). A loan originator organization may also have an NMLSR unique identifier.

Thank you for your guidance.

[jholzknecht]

Angie,

We agree with your conclusion – the unique identifier is not required in general advertisements.

[Author]

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