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.
CUNA’s final rule analysis of the CFPB changes to the TRID rule is now available. The rule, published in the Federal Register this week is effective Oct. 10, with a mandatory compliance date of Oct. 1, 2018.
While proposed changes to the CFPB prepaid accounts rule provide some clarity, it will not be helpful for most prepaid card users and CUNA remains opposed to the rule’s application of Regulation Z to certain prepaid cards.