John - how are we still the creditor if we sell the loans 'servicing released' to an investor? We've signed over the docs with an allonge and they've paid us off. I wasn't confused...?
To borrow a phrase that is being used these days in a political sense, "words mean something." "Creditor" is defined for the purposes of Regulation Z in §1026.2(a)(17) as "[a] person who regularly extends consumer credit that is subject to a finance charge or is payable by written agreement in more than four installments (not including a down payment), and
to whom the obligation is initially payable, either on the face of the note or contract, or by agreement when there is no note or contract."
If your bank closed the mortgage loan in its own name, it will always be the creditor, regardless of how many times the loan is assigned or sold, with or without servicing.