[Sandy]

A MLO’s name and identification # is to be provided to a Consumer home loan applicant. The name is provided on Loan Estimate and other preliminary documents the way it is registered with NMLS website along with their ID#. Can the MLO’s business cards have a slightly different name, for example if they go by their middle name, as long as they have their MLO identification # on it?

[Kimberly Boatwright, CAMS, CRCM]

Per Reg Z section 1026.36(g) and the SAFE Act testing in examiner testing manuals they state
(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.

So it would have to be the name as it is tied to the the NLMS number. However, the NLMS system does allow for an “AKA” if that is also part of the MLO’s record I would think you could possibly use the “AKA” on their business card. I would just caution that since it would be regulator “discretion” to take it since their exam manuals state “as the name appears in the NMLSR”

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