I know under Reg Z the NMLS #’s are required on applications, loan contracts and security instruments(mortgage) but what about HELOC’s? Since HELOC’s are not covered by Reg Z but are covered by the SAFE Act does the NMLS #’s need to be on all of documents or only certain ones?
The NMLS ID disclosure requirements in 1026.36(g) do not apply to HELOCs so the NMLS # isn’t required to be disclosed on the application, note and security instrument. You would still need to follow the SAFE Act disclosure requirements:
(b) A registered mortgage loan originator shall provide his or her unique identifier to a consumer:
(1) Upon request;
(2) Before acting as a mortgage loan originator; and
(3) Through the originator’s initial written communication with a consumer, if any, whether on paper or electronically.