A licensed originator lets an unlicensed assistant sign the 1003 and place the originator unique identifier on it. If the assistant signs as though they were the licensed originator rather than performing authorized clerical entry, is that use of the originator's identity proper?
Correct Answer
B) Improper: it falsely represents the licensed originator as the signer
B. Signing as though one were the licensed originator misrepresents the signer. Form 1003 Section 9 separately identifies the originator, identifier and signature. The stem specifies impersonation rather than authorized clerical entry; an accurate identifier does not make that representation accurate. Scope and exceptions: Do not infer that an assistant may never enter an accurate NMLS ID. Authorized agency signatures, electronic-signature procedures and licensing triggers require separate analysis; no criminal finding is made here. Source: Form 1003, effective 1/2021, Section 9 — https://singlefamily.fanniemae.com/media/document/pdf/form-1003-4 Unique identifier definition — https://www.consumerfinance.gov/rules-policy/regulations/1008/23/
Why This Is the Correct Answer
B. Signing as though one were the licensed originator misrepresents the signer. Form 1003 Section 9 separately identifies the originator, identifier and signature. The stem specifies impersonation rather than authorized clerical entry; an accurate identifier does not make that representation accurate. Scope and exceptions: Do not infer that an assistant may never enter an accurate NMLS ID. Authorized agency signatures, electronic-signature procedures and licensing triggers require separate analysis; no criminal finding is made here.
Why the Other Options Are Wrong
Option A: Proper where the assistant notes on the 1003 who actually signed it
A note does not by itself resolve the stipulated false representation.
Option C: Improper only where the assistant also quoted terms to the borrower
The identity problem does not depend on also quoting terms.
Option D: Proper, because the originator supervised the assistant fully
Supervision does not make impersonation accurate.
Exam Tip
Distinguish data entry from falsely representing who signed.
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