Synergy by Association
  • About Synergy
    • Contact Us
    • Board of Directors
    • Synergy Partner Advisory Committee
  • PROGRAM PARTNERS
    • ABA Insurance Services
    • Bank Marketing Center
    • Bankers Alliance
    • Cornerstone Advisors
    • CRA Partners
    • Discover Debit
    • Hagan Hamilton
    • ICBA Securities
    • KeyState Captive Management
    • ODP Business Solutions
    • ServisFirst
    • Shred-it
    • StrategyCorps
    • Vericast
  • ASSOCIATION ALLIANCES
  • PARTNER TOOLKIT
  • About Synergy
    • Contact Us
    • Board of Directors
    • Synergy Partner Advisory Committee
  • PROGRAM PARTNERS
    • ABA Insurance Services
    • Bank Marketing Center
    • Bankers Alliance
    • Cornerstone Advisors
    • CRA Partners
    • Discover Debit
    • Hagan Hamilton
    • ICBA Securities
    • KeyState Captive Management
    • ODP Business Solutions
    • ServisFirst
    • Shred-it
    • StrategyCorps
    • Vericast
  • ASSOCIATION ALLIANCES
  • PARTNER TOOLKIT

Compliance Alliance Question of the Week

10/4/2018

 
​Question:
Under Reg. Z, the NMLS ID and name would be required on mortgage, note, application, LE and CD for any dwelling-secured loan. Is that correct?
 
Answer:
Reg. Z section 1026.36 requires the NMLS ID to be on the note, security instrument, application, LE, and CD of consumer dwelling secured loans; however, HELOCs are specifically exempt:
 (b) Scope. …Paragraphs (d) through (i) of this section apply to closed-end consumer credit transactions secured by a dwelling. This section does not apply to a home equity line of credit subject to §1026.40…
https://www.consumerfinance.gov/eregulations/1026-36/2018-09243#1026-36-b
 
(g) Name and NMLSR ID on loan documents. (1) For a consumer credit transaction secured by a dwelling, a loan originator organization must include on the loan documents described in paragraph (g)(2) of this section, whenever each such loan document is provided to a consumer or presented to a consumer for signature, as applicable:
(i) Its name and NMLSR ID, if the NMLSR has provided it an NMLSR ID; and
(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.
(2) The loan documents that must include the names and NMLSR IDs pursuant to paragraph (g)(1) of this section are:
(i) The credit application;
(ii) The disclosures required by §1026.19 (e) and (f);
(iii) The note or loan contract; and
(iv) The security instrument.
https://www.consumerfinance.gov/eregulations/1026-36/2018-09243#1026-36-g
 

Comments are closed.
    Picture

    Archives

    March 2020
    February 2020
    January 2020
    December 2019
    November 2019
    October 2019
    September 2019
    August 2019
    July 2019
    June 2019
    May 2019
    April 2019
    March 2019
    February 2019
    January 2019
    December 2018
    November 2018
    October 2018
    September 2018
    August 2018
    July 2018
    June 2018
    May 2018

    Categories

    All
    Compliance

    RSS Feed

    Compliance Alliance offers a comprehensive suite of compliance management solutions.

    To learn how to put them to work for your bank, call (888) 353-3933 or email info@compliancealliance.com.
Copyright © 2023 Synergy by Association, Inc.  All Rights Reserved.
1149 Court Street NE  |  PO Box 13429  |  Salem, OR 97309  |  (800) 468-8558
Picture