Can you add the website address, I would say yes. Should you substitute the website address for the physical address of the provider - that is hard to say as to how acceptable that might be to auditors and examiners. Whether this is a battle you want to engage in would be a business decision.
From the preamble:
The Bureau also does not believe that it would be burdensome for the creditor to include a service provider’s street address. Comment 19(e)(1)(vi)-4 does not state that § 1026.19(e)(1)(vi) requires the provision of addresses. Rather, it explains that to comply with the identification requirement in § 1026.19(e)(1)(vi)(C), the creditor must provide sufficient information to allow the consumer to contact the service provider, and that a creditor that lists the provider’s address, along with its telephone number and the name under which the provider conducts business, would have provided sufficient information. Accordingly, listing an available provider’s street address is not required by § 1026.19(e)(1)(iv)(C), but a creditor that does not list the street address must demonstrate that the information it provided is sufficient information that allows the consumer to contact the service provider.
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