Recently the CFPB published updated versions of the TILA RESPA Integrated Small Entity Compliance Guide and the Guide to the LE and CD Forms. This update clarified that ALL seller charges are required to be disclosed on page 2 of the consumers closing disclosure, regardless of whether a separate CD is provided to the property seller.In order to comply and avoid delays in issuing the initial Borrower CD, you should obtain a seller CD as well from your attorney or title company unless the attorney or title company would prefer to list all seller charges in Section H of the buyer CD that would work as well.
Recently the CFPB published updated versions of the TILA RESPA Integrated Small Entity Compliance Guide and the Guide to the LE and CD Forms. This update clarified that ALL seller charges are required to be disclosed on page 2 of the consumers closing disclosure, regardless of whether a separate CD is provided to the property seller.
In order to comply and avoid delays in issuing the initial Borrower CD, you should obtain a seller CD as well from your attorney or title company unless the attorney or title company would prefer to list all seller charges in Section H of the buyer CD that would work as well.
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