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NMLS # on HELOC & ARM Program Early Disclsoures

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  • #4900
    TheBank
    Participant

    Is the NMLS # required to be on the early HELOC & ARM Program disclosures? The regulation requires it on the application, but I don’t see where it is specifically required on this disclosure. We print packets up so they are ready when consumers inquire, so would it be acceptaqble to not include an NMLS # on these?

    #4904
    rcooper
    Member

    It isn’t specifically required under 1026.36 but you also need to consider the SAFE Act requirements. Here’s a prior post on this topic:
    https://www.jackscomplianceresource.com/forums/topic/loan-docs-that-require-the-nmls/

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