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 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 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/