1003 Signatures from LO (2024)

I have been looking for information in the regulations that speaks to when and where it is required to have a loan officer / originator (person who took the initial application) on the 1003 form. I see plenty of information outlining requirements for the borrower, but am missing where it states if the LO need sign the initial, final, both, or any in between.

Does anyone have direction to where it might clear this up in regulation or where its a requirement for Fannie, Freddie, Etc?

There is no requirement to use a 1003, and to my knowledge, no requirement for the MLO to sign, but chances are if you are selling on the secondary market, your investor will require it.

ETA: Keep in mind that their name and NMLS# does have to be ON whatever application form is used.

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My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

Joker is right. Use of the 1003 (and how it is completed) is an investor or bank policy. Reg B says this about applications and this only pertains to the purchase or refinance of a principal dwelling [required by §1002.13(a)(1)]:

Model application forms are provided in Appendix B to the regulation, although use of a printed form of any kind is not required. A creditor will satisfy the requirement by writing down the information that it normally considers in making a credit decision. The creditor may complete the application on behalf of an applicant and need not require the applicant to sign the application. [Commentary to §1002.4(c) #1]

IOW, there's no regulatory requirement to have any type of application form for loans that are not to purchase/refinance a principal dwelling and when you do have an application for one of those, it doesn't have to meet any requirements except to simply write down what was considered.

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David Dickinson
http://www.bankerscompliance.com