Best Practices: TRID Guidance on Loan Numbers

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Millie Simmons, our Closing Supervisor/Fulfillment Manager in Flower Mound, offers advice on a common question that arises with closing.

Millie, is it acceptable for a loan to close with a Loan ID (loan #) showing ‘TBD?’  In this case, the CD has not yet been disclosed and the lender is inquiring whether it is acceptable to change the Loan ID or close with ‘TBD’ showing on loan docs and CD. 

According to TRID, the loan number must be unique.  ‘TBD’ does not appear to be ‘unique’ per TRID’s guidance as it does not appear tailored towards a specific consumer.  Our opinion is that it would not meet this requirement.  Here’s the Official comment to section 1026.37(a)(12) of Reg Z and a link to it on the CFPB site:

  1. Unique identifier. Section 1026.37(a)(12) requires that the creditor disclose a loan identification number that may be used by the creditor, consumer, and other parties to identify the transaction, labeled as “Loan ID # .” The loan identification number is determined by the creditor, which number may contain any alpha-numeric characters. Because the number must allow for the identification of the particular credit transaction under § 1026.37(a)(12), a creditor must use a unique loan identification number, i.e., the creditor may not use the same loan identification number for different, but related, loan transactions (such as different loans to the same borrower). Where a creditor issues a revised Loan Estimate for a transaction, the loan identification number must be sufficient to enable identification of the transaction pursuant to § 1026.37(a)(12).