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A compliance firm told us that we are required to disclose the name and license number for the settlement agent and a contact person on page five of the Closing Disclosure. But our title company told us that they do not obtain NMLS numbers for individual agents. Are we required to list NMLS numbers for a title agent if the agent has not obtained one? – IBA Compliance Connection

IBA Compliance Connection

Your go to source for compliance!

A compliance firm told us that we are required to disclose the name and license number for the settlement agent and a contact person on page five of the Closing Disclosure. But our title company told us that they do not obtain NMLS numbers for individual agents. Are we required to list NMLS numbers for a title agent if the agent has not obtained one?

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No, we do not believe that you need to include an NMLS number for title agents who have not obtained a license from the state of Illinois. The Official Interpretations of the Closing Disclosure rules state that if a person does not have an NMLS ID, then that space in the Closing Disclosure simply is left blank.

For resources related to our guidance, please see:

  • Official Interpretations, Regulation Z, 12 CFR 1026, Paragraph 38(r), Comment 4 (“Section 1026.38(r)(3) and (5) requires the disclosure of an NMLSR identification (ID) number for each person identified in the table. . . . The space in the table is left blank for the disclosures in the columns corresponding to persons that have no NMLSR ID to be disclosed under § 1026.38(r)(3) and (5); . . . .”)