On 1 July an originator moves from a state-licensed brokerage to a national bank, where she becomes a registered rather than a licensed originator. What happens to her existing NMLSR unique identifier when she changes from state licensing to federal registration?
Correct Answer
D) Her 1 NMLSR unique identifier follows her across both of the employers
D. Her unique identifier remains associated with her. The identifier permanently identifies the individual, not a particular employer. Regulation G expressly addresses employees previously licensed or registered through the registry and the requirements for their transition. Scope and exceptions: Keeping the identifier does not automatically complete registration or preserve operating authority. Employment updates, registration and applicable background-check requirements remain separate. Source: Unique identifier definition — https://www.consumerfinance.gov/rules-policy/regulations/1008/23/ Section 1007.103(a)(1), (a)(4) — https://www.consumerfinance.gov/rules-policy/regulations/1007/103/
Why This Is the Correct Answer
D. Her unique identifier remains associated with her. The identifier permanently identifies the individual, not a particular employer. Regulation G expressly addresses employees previously licensed or registered through the registry and the requirements for their transition. Scope and exceptions: Keeping the identifier does not automatically complete registration or preserve operating authority. Employment updates, registration and applicable background-check requirements remain separate.
Why the Other Options Are Wrong
Option A: Registered originators hold no identifier, which is what licensing adds
Federally registered MLOs also have identifiers.
Option B: She is issued a 2nd identifier, as registration is a different system
Changing pathways does not itself require a second identity.
Option C: Her identifier lapses and a new 1 is issued after 30 days of registration
The stated thirty-day replacement rule does not exist in the cited provisions.
Exam Tip
One permanent identifier can accompany changing licenses, registration and employers.
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