[Chris]

I’m researching a SAFE Act issue and would appreciate your thoughts! We have four employees who strictly do commercial loans only. They defer all things consumer to other loan officers in the bank who handle consumer loans / mortgage loans. For years and years (even prior to my time as compliance officer), we’ve had NMLS ID#’s for them, and have maintained the renewals accordingly each November. I’ve been asked to research whether this is necessary. According to the SAFE Act itself, it looks like they would not be required to maintain their NMLS#’s, and so far I am not able to find anything saying otherwise under Kentucky law.

I’d appreciate other opinions / insight on this topic if anyone can share. Thanks so much for your help.

Topic

[rcooper]

I’d agree that it isn’t required under the SAFE Act and I’m not aware of anything in the KRS that requires registration for commercial lenders. If there is any possibility that these lenders will be involved in residential mortgage loans they should renew their registration.

Under the SAFE Act, Mortgage loan originator means

(1) An individual who:

(i) Takes a residential mortgage loan application; and

(ii) Offers or negotiates terms of a residential mortgage loan for compensation or gain.

[Author]

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