Yes, it is permissible to display your bank’s internal loan number on recorded documents such as mortgages. An interagency interpretive letter confirms that placing a borrower’s account number on recorded documents does not violate the privacy provisions in the Gramm-Leach-Bliley Act and Regulation P, under an exception for actions “necessary to effect, administer, or enforce a transaction.”

Additionally, that interagency interpretive letter describes the primary benefits of placing account numbers on recorded loan documents. “[T]he presence of the account number provides an efficient method for the receiving party (who might be the purchaser or servicer of the loan) to correctly identify the file in which to place the instrument.”

For resources related to our guidance, please see:

• Interagency Interpretive Letter (September 4, 2001) (“We agree that the presence of an account number on a mortgage loan document facilitates the appropriate handling of that document, and note that many mortgage lenders use account numbers on loan documents for this reason. In many cases, ownership of the loan will have changed hands between the time the document is submitted for recordation and the time it is returned from the recording office. The presence of the account number on the mortgage loan documents in such situations is particularly helpful to ensure proper filing. Thus, we believe that the disclosure of the account number on the mortgage loan document fits within the exception provided for by Congress in § 502(e)(1) [and in 12 CFR 1016.14(a)(1)].”)

• Regulation P, 12 CFR 1016.14(a)(1) (“The requirements for initial notice in § 1016.4(a)(2), for the opt out in §§ 1016.7 and 1016.10, and for service providers and joint marketing in § 1016.13 do not apply if you disclose nonpublic personal information as necessary to effect, administer, or enforce a transaction that a consumer requests or authorizes, or in connection with: (1) Servicing or processing a financial product or service that a consumer requests or authorizes; . . .”)

• Interagency Interpretive Letter (September 4, 2001) (“You state in your letter that it is a longstanding common practice for a mortgage lender to place the borrower’s account number on a mortgage loan document to enable the document to be tracked and placed in the proper file once the document is recorded and returned from the recording office. You also state that the return of the document might take several months, and you note that the presence of the account number provides an efficient method for the receiving party (who might be the purchaser or servicer of the loan) to correctly identify the file in which to place the instrument.”)