Since someone's loan number does not personally identify them, it becomes very confusing as to where they got this idea.
4. Application or loan number. An institution must ensure that each identifying number is unique within the institution. If an institution's register contains data for branch offices, for example, the institution could use a letter or a numerical code to identify the loans or applications of different branches, or could assign a certain series of numbers to particular branches to avoid duplicate numbers. Institutions are strongly encouraged not to use the applicant's or borrower's name or social security number, for privacy reasons.
Even the proposal had more examples than the final regulation, and none of them were a loan number either:
Proposed comment 4(a)(1)(i)–2 explains that information that could be used to directly identify the applicant or borrower includes but is not limited to the applicant’s or borrower’s name, date of birth, Social Security number, official government-issued driver’s license or identification number, alien registration number, government passport number, or employer or taxpayer identification number.
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