Reg Z – How should the Costs at Closing section be completed on the Loan Estimate?

Compliance > Regulation Z - TILA / TRID Specific > Loan Estimates
Q:  How should the Costs at Closing section be completed on the Loan Estimate?
 
A:  Regulation Z has technical requirements for the completion of the Costs at Closing section.  While creditors should review regulatory conditions and commentary, a general description of the requirement is as follows: 
 
The Costs at Closing section has two components, as follows: 
 
  • Estimated Closing Costsprovides a total amount of closing costs as itemized on page 2
  • Estimated Cash to Close – provides a total cash amount the consumer is expected to bring, or will be paid to the consumer, at consummation as itemized on page 2
The Costs at Closing table, as excerpted from the model form H-24(A) appears as follows:
 
 
The ALTERNATIVE Costs at Closing table, as excerpted from the model form H-24(G) [for transactions without a seller] appears as follows:
 
 
In comparing the two tables, the alternative table includes two check boxes in the estimated cash to close section to indicate whether the disclosed estimated amount is due from or to the borrower.  As the CFPB clarified in the webinar referenced below, use of the alternative disclosure for transactions without a seller is optional.
 
 
ADDITIONAL INFORMATION – The regulatory citation for this topic is 12 CFR 1026.37(d). 
This disclosure is also addressed in the CFPB's “Guide to the Loan Estimate and Closing Disclosure forms,” which may be found here - http://www.consumerfinance.gov/regulatory-implementation/tila-respa/
This was also discussed in the CFPB's October 1, 2014 webinar - Completing the Loan Estimate, which may be found here - http://www.consumerfinance.gov/regulatory-implementation/tila-respa/

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