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As the rules don’t clearly address this, one question I have received is this: Does the NMLS number need to be included on an Adverse Action Notice?

Disclosure requirements can often be a bit tricky when a mortgage loan is denied within the first three days of application.  Many loan officers incorrectly believe that the Adverse Action Notice is the only disclosure required when a loan is denied within the first 3 business days after application.  That is certainly not the case. For example, while TRID disclosures are not required for loans denied in the first three days of application, Regulation B still requires the delivery of an appraisal notice and certain situations still require the delivery of the FCRA credit score exception notice (https://www.compliancecohort.com/blog/credit-score-exception-notice-for-denied-applications).

So, what about the NMLS Number?

While the NMLS number is often provided to an applicant prior to the delivery of the Adverse Action Notice, there are some cases where the NMLS number will not have been previously provided.  For example, if a mortgage application is taken by phone and the application is denied within the first three business days after application, the applicant may not have been previously provided with any written communication.

Specifcially, SAFE Act rules require the delivery of an MLO’s unique identifier (NMLS #) to a consumer in three cases:

Therefore, in cases where the Adverse Action Notice is the first written communication to an applicant, an MLO’s unique identifier (NMLS #) must be provided with the Adverse Action Notice.

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