Q: In Regulation G, what are the unique identifier requirements?
A: Unique Identifier – 12 CFR 1007.105
When an MLO registers with the Registry, he or she receives a unique identifier — a series of numeric characters assigned for life. The unique identifiers allow MLOs to be tracked if they move between state and federal jurisdictions and/or change employers, and help consumers to find certain information about a particular MLO when they search on the Registry’s consumer access portal. The MLO information that is publicly available on the consumer access portal will ultimately include federal and state registrations and licenses held, the MLO’s employment history, and publicly adjudicated disciplinary and enforcement actions, if any.
To make sure that consumers have access to an MLO’s unique identifier before committing to a mortgage loan transaction, an MLO must provide the unique identifier upon request (orally or in writing), before acting as an MLO (orally or in writing), and in any initial written communication (paper or electronic) from the MLO to the consumer (such as a commitment letter, good faith estimate, or disclosure statement). MLO unique identifiers may be used on written materials or promotional items distributed by the institution for general use, for example on loan program descriptions, advertisements, business cards, stationery, notepads, and similar materials; the SAFE Act regulation does not prohibit such use.
The regulation also requires institutions to make MLO unique identifiers available to consumers in a practicable way. This could be achieved, for example, by:
Directing consumers to a listing of registered MLOs and corresponding unique identifiers on the institution’s website;
Posting the information prominently in a publicly accessible place, such as a branch office lobby or lending office reception area; and/or
Establishing a process to ensure that institution personnel provide MLO unique identifiers when requested by consumers from employees other than the MLO.