[Angie Cowell]

Under the Transaction Information if there is a seller we are to list the seller name and address per 1026.38(a)(4)(ii). If we are preparing a separate Closing Disclosure for the seller, does the seller name & address have to be included still on the borrower’s Closing Disclosure? Our two systems, Laser Pro & Mortgage Builder are not including seller name and address on the borrower’s Closing Disclosure when we are doing a separate seller disclosure. We feel like we are missing something in the regulation.

[rcooper]

I’m with you. After looking at 38(t)(5)(v)-(vi) I don’t see where the seller information can be omitted even if the CDs are separated, so I would agree that it does need to be included unless they can prove otherwise. If you can get in contact with a rep ask them what they are basing that opinion on. There may be something buried in the preamble (althought I did search and could’t find anything that supports that) or they may have gotten an unofficial opinion from the CFPB.

[kmeade]

We use Laser Pro (we do not use Mortgage Builder)and when we prepare the Closing Disclosure with the separate Seller’s Closing Disclosure it does list the Seller’s name and address on both documents. Contact me and I can forward copies of samples I have produced. kmeade@mycgb.com

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