In the requirements given for the “Additional Information About This Loan” section on page 3 of the Loan Estimate, both 12 CFR § 1026.37(k)(1)&(2) state that: “In the event the [creditor, mortgage broker, or loan officer] has not been assigned an NMLSR ID, the license number or other unique identifier…shall be disclosed.”
Similarly, regarding the “Contact Information” section on page 5 of the Closing Disclosure, Ibid. 38(r)(3)&(5) says: “In a separate table, under the heading ‘Contact Information,’ the following information…Nationwide Mortgage Licensing System & Registry (NMLSR ID) identification number, labeled ‘NMLS ID,’ or, if none, license number or other unique identifier issued by the applicable jurisdiction or regulating body…”
Based on these regulatory requirements, as well as the associated commentary and examples, the State license number or other unique identifier should only print if no NMLSR ID exists for that entity or individual. Therefore, Docutech will be slightly modifying the document logic in these sections of the Loan Estimate (Cx18565) and Closing Disclosure (Cx18566) to ensure that, if an entity or individual uses an NMLSR ID, the State abbreviation and license number will not print.
These change will be in effect on June 7, 2016. If you have any questions or concerns about these changes, please contact Client Support at 1.800.497.3584.
DR 199161
Update: Due to conflicting instructions between the Regulation and the Official Commentary, some clients have expressed an interest in printing both the NMLSR ID and the State license number for the same entity on the Closing Disclosure. To accommodate this we have created a new field, 103800 Allow Both State License ID and NMLS on Closing Disclosure, and will include it in the document logic on the CD. This change will be available immediately.