[FCSF2016]

I would very much appreciate an explanation or example of when we would use K04 versus K05-07 under the Borrower’s Transactions on the CD. Once in a while we will have a purchase plus construction loan (we do single close construction loans) and we use K04 to disclose the construction funds being withheld–is this correct? Thank you so much!!

[jholzknecht]

The commentary explains that the construction loan proceeds appear on line K04, which is consistent with your practice. The commentary does not provide examples of items that are disclosed in the Adjustment section (Line K05 – 07).

[FCSF2016]

As a follow question–can additional lines be added under the first portion of Section K? In other words, can we move line K.05 above the Adjustments section to show additional payments to third parties? We have a purchase loan with additional purposes (construction and refi) so they aren’t items that really fit under Adjustments. Thanks!

[jholzknecht]

There is no provision that allows you to move line 05. Comment 38(j)-2. states, “Additional pages may be attached to the Closing Disclosure to add lines, as necessary, to accommodate the complete listing of all items required to be shown on the Closing Disclosure under § 1026.38(j) and (k)… A reference such as “See attached page for additional information” should be placed in the applicable section of the Closing Disclosure.

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