CFPB TRID Sec. 11.7 - When a separate disclosure is provided to the seller, what information is required to be disclosed on the seller’s Closing Disclosure?

Compliance > Regulation Z - TILA / TRID Specific > Closing Disclosures
Q:  When a separate disclosure is provided to the seller, what information is required to be disclosed on the seller’s Closing Disclosure?
 
A:  When separate disclosures are provided, the seller must be provided with the disclosures in section 1026.38 that relate to the seller’s transaction reflecting the actual terms of the seller’s transaction. Model form H-25(I) of appendix H to Regulation Z illustrates the seller’s modified Closing Disclosure, which is required to disclose the summary of the seller’s transaction, contact information for the real estate brokers and settlement agent, and Loan Costs and Other Costs paid by the seller at or before closing. (§§ 1026.38(t)(5)(v) and (t)(5)(vi))
 
To provide separate disclosures for the consumer or seller, a creditor may:
  • Leave the applicable disclosure blank on the form provided to the other party;
  • Omit tables or labels, as applicable, for the form provided to the other party; or
  • Provide the seller with a modified version of the form provided in appendix H. (Comment 38(t)(5)(v)-1)
 
This Closing Disclosure / CD information can be found in the CFPB's TILA-RESPA Integrated Disclosure rule compliance guide - http://www.consumerfinance.gov/regulatory-implementation/tila-respa/
 

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