Starting in 2018, an institution will report the NMLS ID for the mortgage loan originator. This is a unique number that is assigned to a loan originator through the National Mortgage Licensing System & Registry. The loan officer does not necessarily have to have one in order to provide loan originating services. If they are not required to have a NMLS ID number and they have not obtained one, then this data point should be reported as being “not applicable”.
There are some instances where the loan officer has obtained a NMLS ID but can originate a loan without one as it is not required by the state. The NMLS ID number should be reported on the HMDA LAR regardless of this, unless the transaction falls into one of two categories. First, if it is a purchased loan that is subject to 12 CFR 1026.36(g) (consumer credit transaction secured by a dwelling) and was originated prior to January 10, 2014. The other is if it is a purchased loan not subject to 12 CFR 1026.36(g) and it was originated prior to January 1, 2018. In these instances, this data point should be reported as being “not applicable”.
There are times when there is more than one loan officer associated with that particular transaction. If this occurs, the financial institution should report the NMLS ID of the loan officer who had the primary responsibility for the transaction as of the date of action taken.
For more information on HMDA regulations, 2018 data point changes or our HMDA compliance services, please call Rhonda Wannemuehler or Betsy Reynolds at 855-734-7655.