Itemize Amounts on the TIL?

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Question:

I have a real estate transaction with a buyer and seller. We have prepared the TIL and the disbursement disclosure. My processing department has put on the buyer's documents that the proceeds of the loan will be paid to the seller’s bank in the amount of $51,094.34, and to the seller in the amount of $8,905.66. These amounts totaling $60,000.00 Do I itemize these amounts on the TIL to the buyer, or do we just show a total amount of $60,000 to the seller. Compliance is telling me that it should be itemized to the buyer, and I disagree.

Answer:

Why would you have a TIL itemization of the amount financed? That's what the HUD Settlement statement is for; however, if you insist on using the itemization, then it should be itemized. The $51K+ is being paid to seller's bank on the borrower's behalf and the $8K+ is being paid directly to the seller on the borrower's behalf. From 226.18: (iii) Any amounts paid to other persons by the creditor on the consumer's behalf. The creditor shall identify those persons.

First published on BankersOnline.com 1/18/10