The CFPB has created a new subsection of Regulation Z (12 CFR § 1026.36[g]), which requires that the names and NMLS numbers of the loan originator primarily responsible for a loan and the loan originating company he works for, be disclosed on several different loan documents, one of which is the loan application.
There is some ambiguity in the regulation as to which entities these items of information should be disclosed for; whether for the broker and his originator, for the lender and his originator, or all four entities. We have taken a conservative approach and will be disclosing the information for all four in our promissory notes and security instruments.
In regards to the loan application, the vast majority of originators use the FNMA/FHLMC Uniform Residential Loan Application Form 1003/65 (URLA). The URLA has, for several years, disclosed the loan originator’s name and NMLS information, as well as that of the company he works for.
The URLA has not been modified to include the disclosure of more names and NMLS numbers than these two entities. In order to accommodate the more conservative approach of disclosing the appropriate information for all four entities, we will be providing, upon request, an addendum to the URLA (Cx18212) which will contain this information.
Once requested, Cx18212 will print per copy of the URLA (Cx4193) in Initial, Processing, Underwriting, and Closing packages, and when the application of the loan is January 10, 2014 or later. Like Cx4193, it will not print for HELOCs.
This document will be available upon request beginning January 3, 2014. If you have any questions or concerns about these changes, please contact Client Support at 1.800.497.3584.
December 31, 2013