Regulation G (12 CFR 1007) defines a residential mortgage loan as (in part) any loan primarily for personal, family, or household use that is secured by a mortgage, deed of trust, or other security interest on a dwelling or residential real estate upon which is constructed or intended to be constructed a dwelling, and includes refinancings, reverse mortgages, home equity lines of credit and other first and additional lien loans.
Regulation Z - specifically 1026.36(g), identifies the loan documents which must include the names and NMLS number. These documents are the credit application, disclosures required by 1026.19 (e) and (f) (loan estimate and closing disclosure), the note or loan contract, and the security instrument.
Is it accurate to have the name and NMLS number listed on the application, note/loan contract, and security instrument for home equity lines of credit? I am being told that the NMLS number is not required to be on HELOC documents and that it only applies to closed end credit agreements.
Thank you