[Anonymous]

What should be done when a settlement agent says their company does not have a KY License ID for contact information on the CD? We have had a couple instances where law firms are the settlement agents and the attorney is the contact; a number is provided for the attorney but none for the firm. Do we use the contact’s number in both places? The absence of a number for the firm was noted in an audit. Thanks1

[rcooper]

My understanding is that it would be left blank if they don’t have an ID number.

5. License number or unique identifier. Section 1026.38(r)(3) and (5) requires the disclosure of a license number or unique identifier for each person (including natural persons) identified in the table who does not have a NMLSR ID if the applicable State, locality, or other regulatory body with responsibility for licensing and/or registering such person’s business activities has issued a license number or other unique identifier to such person under § 1026.38(r)(3) and (5). The space in the table is left blank for the disclosures in the columns corresponding to persons who are not subject to the issuance of such a license number or unique identifier to be disclosed under § 1026.38(r)(3) and (5); provided that, the creditor or settlement agent may omit the column from the table or, if necessary, replace the column with the contact information for an additional person.

[Author]

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