Answer:
No. You can use a Closing Disclosure with the “optional alternative disclosures” of the Costs at Closing table on page 1 and of the Calculating Cash to Close table on page 2 if the Closing Disclosure for the primary loan includes all of the seller’s costs for the real estate transaction. No seller costs can appear on the Loan Estimate for the simultaneous subordinated loan.
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Closing Disclosures under TRID 2.0