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Substitute form for a Closing Disclosure

Answered by: 
John Burnett

Question: 
May a seller’s statement be provided by the title company in lieu of a seller’s closing disclosure? It contains all of the same information as provided in Model form H-25(I) in Reg Z. (https://www.consumerfinance.gov/rul...e7023baceb466835a39ca4fa95107c1f1037ca3c) This is a purchased loan and we are performing quality control checks on a file.
Answer: 

In general, the H-25 model forms should be used. Whether the "seller's statement" is an acceptable substitute will depend on the format to some extent, but certainly on the items and information included on the disclosure.

One would have to have the document in hand to be able to offer an opinion.

First published on 11/20/2022

Filed under: 
Lending
Filed under lending as: 
Reg. Z
Closing Disclosures

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