Settlement Agent & File# on Closing Disclosure

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Question:

The closing Information box on our disclosure has "Settlement Agent & File#." If the lender is the settlement agent, (for a refinance) are they listed as the agent and the file number or can it be the loan number used?

Answer:

You have two choices. You either leave the two entries blank or you list the bank with whatever reference number you would like (typically the loan number). Since the bank is closing their own loan, there is no settlement agent involved, One cannot be an "agent" for themselves. However, this is one area on which the CFPB has not been exceedingly clear, so it remains a business decision.