Vermont Admin. Code 4-2-3:4(a) requires that before a Mortgage Broker takes any fee or collects any charges, or at the time the prospective borrower submits a signed application, whichever occurs first, the Broker and the prospective borrower must both sign a contract that sets forth (i) the particulars of the service to be performed, (ii) that the broker shall represent the interests of the prospective borrower rather than the lender, and (iii) all fees received by the broker for services. Subsection (c) requires that this contract to be approved by the Commissioner and the appendix contains a sample form that is approved by the Commissioner.
Upon review of this sample form and comparing it to our copy of this form (cx3594), we will be making an adjustment to one of the fields. Near the bottom of the model form it requires the broker NMLS number. Currently, the broker license number field (dt_BrokerLicenseNumber/@v) is being used, but we have determined the Mortgage Broker NMLS field (dt_MortgageBrokerNMLS/@v) would be more commonly used. Because of this we will be updating the logic to input the NMLS field if sent, if not then we will input the license field.
This change will take effect on November 25, 2021. Questions or concerns about this change should be directed to Client Support at 1.800.467.3584.