closing-disclosure

name	closing-disclosure
description	Drafts and reviews TRID-compliant U.S. residential Closing Disclosures, assembling all five pages, comparing to Loan Estimates, checking tolerance buckets, and flagging re-disclosure triggers. Use when working with closing disclosures, CDs, TRID, Regulation Z, LE comparison, tolerance cures, cash-to-close, settlement statements, or closing compliance review.

Closing Disclosure

Produce a complete five-page Closing Disclosure per CFPB Form H-25 and a compliance review memo.

Quick Start

1. Confirm role: lender, settlement agent, borrower counsel, or seller counsel.
2. Gather: loan terms, Loan Estimate(s) with dates, itemized closing costs, escrow/prepaids, payoffs/prorations, closing timeline.
3. If attorney role: produce issue list and client summary — not a lender-signed CD.

Core Workflow

1. Data Intake by CD Page

Page	Section	Required Inputs
1	Closing/transaction/loan info	Issue date, closing/disbursement dates, borrower(s), seller(s), property, sale price, lender, loan term, purpose, product, loan ID
1	Loan terms	Loan amount, rate, P&I, prepay penalty, balloon
1	Projected payments	P&I, MI, escrow, totals by period
1	Costs at closing	Total closing costs, lender credits, cash to close
2	Loan costs (A–C)	Origination, lender-required services, shopped services
2	Other costs (E–H)	Gov fees, prepaids, escrows, commissions, owner title
2	Totals (D, I, J)	Subtotals and lender credits
3	Cash to close	LE vs CD comparison with change reasons
3	Summaries (K–N)	Borrower/seller transaction summaries, credits, payoffs
4	Loan disclosures	Assumption, demand, late fee, neg-am, partial payments
4	Escrow account	Escrowed vs non-escrowed costs, waiver fee
4	ARM tables	AP/AIR tables (if applicable)
5	Loan calculations	Total of payments, finance charge, amount financed, APR, TIP
5	Other disclosures	Appraisal, contract details, liability, refinance, tax
5	Contact info	Lender/broker/RE agent/settlement agent identifiers

Flag any missing field as MISSING.

2. LE Comparison and Tolerance Analysis

Bucket	Rule	Typical Items
Zero tolerance	No increase over LE	Lender/broker fees, transfer taxes, non-shoppable services
10% cumulative	Aggregate increase ≤ 10%	Recording fees, shoppable services on lender list
No limit	May change if good faith	Prepaids, escrow, non-list providers, owner title

For each bucket, compare LE vs CD amounts and compute variance. If a zero-tolerance or 10% violation exists without a valid revised LE, state the cure amount and responsible party.

3. Re-Disclosure Triggers

A new 3-business-day waiting period is required if any of:

• APR increases > 0.125% (fixed) or > 0.25% (ARM)
• Loan product changes (fixed/ARM, term, IO, neg-am)
• Prepayment penalty added

4. Delivery and Timing

CD issue date:
Delivery method:    hand / mail / electronic
Deemed receipt date:
Earliest consummation date:

Business-day counting excludes Sundays and federal holidays. [VERIFY jurisdiction-specific rules]

Pitfalls and Checks

• Use CFPB Form H-25 structure; do not rewrite statutory disclosure text unless a state addendum requires it.
• Settlement agent role: confirm lender-supplied loan terms before finalizing pages 1 and 5.
• Lender role: validate settlement fees and prorations from settlement agent before issuing final CD.
• Always reconcile cash-to-close with the transaction summary and payoffs.
• For state transfer taxes, recording fees, and proration rules, require jurisdiction-specific confirmation. [VERIFY]
• Cite: 12 CFR 1026.38, 12 CFR 1026.19(e)(3), 12 CFR 1026.19(f), TILA, RESPA.