LEI and HMDA News Links + Compliance Updates

Obtaining an LEI and Using the MIN as the Second Component of the Universal Loan Identifier (ULI)

As the January 2018 effective date for the new Home Mortgage Disclosure Act (HMDA) requirements fast approaches, many MERS® System Members (Members) have started to focus their attention on obtaining an LEI and generating ULIs.

Here are two common questions that have been asked by Members:

Question #1 - How does my organization obtain an LEI?

If your organization needs to apply for an LEI or renew or update its existing LEI, you can access MERSCORP Holdings, Inc.’s online LEI Registration and Renewal Services.

Complete the required fields in the secure online application and submit payment by credit card. Once your organization is approved for an LEI or your existing LEI is renewed, your designated LEI contact will receive a confirmation email within three to five business days. This email will include your organization’s LEI.

Question #2 - Can the Mortgage Identification Number (MIN) be used as the second component of the ULI?

Yes. The existing structure and requirements for the MIN meet the criteria for the second component of the ULI, as the MIN is 18 digits, unique to each transaction, cannot be duplicated, and does not directly identify the borrower associated to the loan transaction (e.g. does not contain the borrower’s name or social security number).

Other reasons Members may opt to use the MIN as the second component of the ULI include:

  • Virtually all Members have MIN-generation capabilities built into their loan origination system (LOS) or other industry platforms.
  • The MIN associated with a loan remains constant whereas loan numbers change often when loans are bought and sold.
  • A MIN can be generated for a loan that does not close or for a loan that does not end up closing with Mortgage Electronic Registration Systems, Inc. (MERS) named as mortgagee.
  • The MIN provides one additional reference point within the ULI, as the MIN can be used to look up the current servicing Member using MERS® ServicerID or the MERS® System.

Your Next Steps:

  1. Determine whether your organization is a covered institution under HMDA and whether it already has an LEI. If your organization needs to obtain an LEI or update or renew its existing LEI, start the application process.
  2. If you are considering the MIN as the second component of the ULI, contact your ULI generation source (typically LOS vendors) to determine if they can support it.
    • Mortgage Cadence already supports the MIN as the second component of the ULI (ELC lending platform).
    • PCLender, now part of Fiserv, plans to support the use of the MIN as the second component of the ULI by the end of 2017.

Questions? Please email us at [email protected]