Is there more than one kind of Closing
Disclosure ("CD")?
The CFPB designed three different CDs: one
for the buyer in a purchase
transaction, one for
the seller, and one for
refinance borrowers. The Buyer's
CD has all the information for both sides of the transaction, like the HUD-1.
The Seller CD has just the info from the seller's side and
is two pages long.
How do I open a new file for a CD closing?
Once you have opened a new file, on the Names tab, click the list in the
Attributes section to choose the 2015 Disclosure Form. You should do this BEFORE
you enter any financial information. Your Pages 1, 2 and 3 tabs
for will change from HUD-1 pages to CD pages.
Why is my screen showing me
several pages of the CD at the same time?
On large, high-resolution monitors, Closing Center can show
you multiple parts of the CD all on one data entry
screen. This is a "power user" mode that you might like once you become
more familiar with the CD. To turn it off, you need to be on the CD
data entry screens, and then press Alt-A on your keyboard. Click the "Form"
tab and un-check "Maximize Display."
Can I merge a CD from info entered on the HUD-1 screens?
No. You must fill in the CD screens to merge a CD.
Can I change a HUD-1 file to a CD file?
The fields on the CD do not match the HUD-1, so none of
the data will convert to the new format. Doing this may even cause problems
with your CD financial data. For this reason, it is not recommended to copy a
HUD-1 file to a new file that you intend to use for a CD.
How do I merge/print the different CDs?
On the Print Documents screen, the HUD-1 batch will have a new label -
"Disclosure." The buyer's CD is called CD. The seller CD (CDSeller) will
merge from the same information you are entering on the screens for the
buyer's CD. The refi CD (CDRefi) will be in the batch instead if the
file is a refinance.
How do I enter the Closing, Transaction & Loan
Information on Page 1?
Most of this information fills in automatically
from the Names and Financial tabs. There are a few fields you fill in yourself.
How does the rest of Page 1 get filled in?
Most of the information on Page 1
will come from your lender. There are a few items, such as the Estimated Escrow,
that will automatically calculate from the escrow section on Page 2.
How will I know what to enter, if anything, when an answer on Page 1 is Yes?
An explanation is always required if the answer is Yes. Your lender should
be supplying this information.
How is the Estimated Taxes, Insurance & Assessments total calculated?
This number is the total monthly escrowed and non-escrowed costs, exclusive
of mortgage insurance. Often it will be just the total of monthly property
taxes and homeowner's insurance. However, there will be times you need to
manually calculate the total, as it can include amounts that are not otherwise
disclosed on the CD, such as the monthly cost for condominium fees. The total
should match the total of those same two items in the Escrow Account section
on Page 4.
What if I have additional items for
Estimated Taxes, Insurance & Assessments?
We are not allowed to add more lines to the three shown on the sample
form. If you have more than three, list one item next to Other, but make sure
your total includes all the items.
How do I override an automatically calculated figure
on the CD screens?
Right-click the figure, then click "Control," then check the "Override" box.
More features will soon be added to the program to make this easier and to give
you additional right-click options.
On Page 2, can I delete standard entries to make room for more items?
Certain entries must be in place whether they are being used or not. This
is best understood by looking at the CFPB's blank CD form, but the line
items are A.01, E.01-02, F.01-04, and G.01-03.
What do I do about recording fees other than Deed and Mortgage?
We are not allowed to add line items or otherwise list separately the recording
fees for all the additional items to be recorded. As a consequence, the
subtotal for section E will usually be a number that is not the total of
the fees that are listed. It will have to be calculated and entered manually.
Why don't my monthly taxes fill into the escrow section?
The annual property tax figure on the Financial tab has
been de-coupled from the monthly tax
figure in the Initial Escrow section (G.). This was done because there have been too many
instances of users needing to enter a number in the Escrow section that is higher than the amount
calculated from the previous year's annual amount.
How are simultaneous loan and owner's policy
premiums apportioned?
The loan policy is disclosed at full price, and the
owners total cost less the loan policy and any simultaneous issue fee.
This is the same as most Standard Conveyancer users have always shown it.
Interestingly, some states have laws which require the opposite, so there
is a conflict between state law and the CFPB regulation.
Where are lender credits entered?
Lender credits go on the bottom of
page 2, in section J, as a negative number. The lender credit reduces that
borrower's Total Closing Costs in J. You do not enter lender credits like
you would on the HUD-1 Page 1, as an item paid on behalf of the borrower.
What is the difference between Page 2 Seller-paid costs and a Page 3 Seller
Credit?
If the seller pays closing cost included on Page 2, the
cost is listed in the seller column. Seller credits on Page 3 are for an
additional Seller concession for something that is not a closing cost,
such as a credit to cover the repair of a problem discovered just before closing.
How is the Cash to Close section filled in?
Please see our
annotated sample CD for an illustration,
and the
CFPB Guide for more information.
How are Broker commissions shown when there is a Broker-held
deposit?
Broker commissions are always listed with the full payment in
section H. The practice of showing only the additional amount being paid
to brokers (as on HUD-1 Page 2, with the deposit held by broker on Page 1)
does not apply on the CD. (See
http://www.consumerfinance.gov/eregulations/1026-38/2013-28210#1026-38-g-4-i,
then click to show the Interpretation for 38(g)(4).) A
credit for the deposit retained by the broker should be
entered on page 3 in section N.
What if the Broker is holding excess deposit?
Excess deposit is still
listed as an amount subtracted from the total due to seller, in this case on line N.01.
How do I figure the Loan Calculations on Page 5?
These are Truth-in-Lending numbers that should come from the lender.
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