[jeffcumbee]

I am sorry if this was covered in one of our sessions. As I have been looking over some sample disclosures generated from our lo software, I noticed on the closing disclosure (page 1) under Taxes, Insurance, and Assessments, the regulation (g)(vi)states “a reference to the information disclosed pursuant to paragraph (g)(3) of this section”. (g)(3) is the disclosure on Page 2 under “other costs”, “Initial Escrow Payment at Closing”. However, our lo software disclosures, and the examples from the CFPB, both reference the “Escrow Account” information on page 4. Am I missing something or are these forms referencing customers to the wrong escrow information? Or, since the forms were created prior to the regulation, does the regulation refer to the wrong section?

[rcooper]

jeffcumbee,
I’m having trouble finding exactly what you are talking about in relation to the tax, insurance and assessments information from page 1 of the CD (1026.38(c)(2) says there needs to be a reference to (l)(7) which is page 4). Can you provide me with the full citation for the language you are looking at in the regulation? That should help me answer your question.

Thanks.

[jeffcumbee]

Ok. I think I see where I messed up. I was looking at 1026.37, instead of 1026.38. I see now where 1026.38 (c)(1) requires all the information from 37 (c) (1)-(4) other than 37 (c)(4)(vi) which is the reference to (g)(3). Thanks for pointing that out, sometimes I get lost between 1026.37 and 1026.38 because a lot of the 38 just references 37.

[Author]

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