Information Center

The AIR and AP tables which may appear at the bottom of page four may only appear when they contain information. They will be displayed if the loan has an adjustable payment feature (AP) and an adjustable interest rate feature (AIR). If only one feature, then only one table will appear. In your case your client's loan is likely a fixed rate product. Fixed rate products generally do not include adjustable payment or adjustable interest rate features. Under those circumstances, no tables are allowed to appear in blank under TRID rules.

On the “__License ID” line the license number or unique identifier associated with the legal or trade name of the individual or company employing the natural person who interacts with the consumer is disclosed.

In the case of an entity, that will be the number assigned by the regulatory body in charge of registering the business activity, such as the Florida Department of State. If the entity is not registered, the field will be left blank. If a sole practitioner, the Florida Bar license number will be disclosed. In some situations, the attorney could be both the entity and individual contact for disclosure purposes if no employee has either a license or other unique identifying number for purposes of the form.

On the “Contact ___ License ID” line the license number, or other unique identifier, of the natural person who interacts most frequently with the consumer is disclosed.

In the event that person does not have either number, the number of the most immediate supervisor who has such a number will be disclosed. The rule is more concerned that a number be disclosed even if that is not the employee who interacts most frequently with the consumer!

Attorneys and Florida Registered Paralegals will disclose a Florida Bar license number; Certified Paralegals will disclose a NALA account number; and licensed title agents who are not attorneys will disclose a Florida Department of Financial Services license number. (Note: lenders may have a more restricted view of rule interpretation and not allow use of Florida Certified Paralegal or NALA account numbers. This is because the commentary to the rule found at 38(r)-6 says not to use the name of an individual who is “only performing clerical functions.”)

The Closing Disclosure forms require contact information for the entity as well as an individual within the company. Failure to disclose relevant information could be considered a rules violation subjecting the lender to a significant penalty. If you choose not to disclose this number, the lender may refuse to do business with you and your firm.

If you are concerned about the privacy of your information, you should know that the requested license ID is a matter of public record. It is NOT your social security number.

You will need both the license number of the agent and the license number of the agent’s real estate broker to complete the Contact Information table. The broker’s state-issued license number will go on the first “FL License ID” line and the agent’s license number will go on the second “FL License ID” line. You can search the Florida Department of Business & Professional Regulation website for license information at https://www.myfloridalicense.com/wl11.asp

Just like the HUD-1, the rules do not require signatures other than when the Confirm Receipt disclosure is included. The lender will direct you if they want signatures on the Closing Disclosure.

You may also choose to have the parties sign your own settlement statement for your file. If you do, the lender will likely want a copy.

The Closing Disclosure form is difficult to use as a disbursement document for a variety of reasons. DoubleTime^® will continue to seamlessly produce a “Balance Sheet” report to provide that solution for you. You might also rely upon a separate settlement statement for the participants and use it as a disbursement document. If you do so you must be prepared to provide a copy to the lender.