- Business Rules
What name is used for the Creditor/Lender?For transactions without a mortgage broker; the creditor making the disclosures must be identified as the creditor. Creditor is a person who regularly extends consumer credit that is subject to a finance charge or is payable by written agreement in more than four installments (not including a down payment), and to whom the obligation is initially payable, either on the face of the note or contract, or by agreement when there is no note or contract.
On transactions with a mortgage broker; the name and address of the creditor must be disclosed, if known, even if the mortgage broker provides Loan Estimate to the consumer. The mortgage broker must make a good faith effort to disclose the name and address of the creditor, but if the name of the creditor is not yet known it may be left blank.
For transactions with multiple creditors; the creditors must agree among themselves which creditor must comply with the requirements that Regulation Z imposes on any or all of them.
Citation(s): §1026.37(a)(3); Commentary ¶37(a)(3)-1 & -2; §1026.17(d) and §1026.2(a)(17)
CFPB announcement regarding the delay of TRID
The full statement from CFPB Director Richard Cordray can be viewed here