Q What loan originator information must be included on mortgage documents under the Reg Z loan originator rule?
A The credit union must include the following on mortgage loan documents provided to a consumer or presented to a consumer for signature:
Its name and Nationwide Mortgage Licensing System & Registry (NMLSR) identification number (if applicable); and
The name and NMLSR ID (if applicable) of the individual loan originator with primary responsibility for the origination. The NMLSR ID is a number assigned by the Registry as required by the SAFE Act.
The following documents must include this information: the credit application; the note or loan contract; and the security instrument. These requirements apply to closed-end consumer credit transactions secured by a dwelling— Reg Z, Section 1026.36(g).
Visit CUNA’s compliance blog— “CompBlog”—at cuna.org. Email firstname.lastname@example.org with questions or ideas, and keep the conversation going with your peers on COBWEB—CUNA’s compliance listserv.
The Department of Labor will publish its final rule Wednesday regarding employees’ eligibility for overtime pay--a rule which CUNA believes will have unintended negative consequences for credit unions, particularly smaller credit unions and those in non-metropolitan areas.
Further CUNA analysis of the U.S. Department of Labor’s overtime rule found minor relief, but CUNA remains concerned about the increased burden on credit unions. Several CUNA-suggested changes were included in the final rule.
Six federal agencies published guidance last week designed to ensure all depository institutions are aware of expectations when it comes to deposit reconciliation. CUNA’s compliance explains what it means for credit unions in a recent CompBlog post.