Has anyone encountered a title company using a HUD for a non-RESPA loan when a GFE isn't provided? Is that a problem?

We use HUDs on non-respa loans for vacant land and bridge loans. All of the title companies we have used have provided us with a pre 1-1-2010 HUD. In HUD's F.A.Qs. they state that giving a HUD on a non-respa applicable loan does not make respa applicable.

I read that in the FAQs and also read in the HUD instructions that there isn't an objection to using the HUD when not legally required to. We were told by our state's banking association to not use a HUD if it is not a RESPA loan. I'm not sure if that's their interpretation or if something has been issued by HUD.

That would be their interpretation and the basis for that interpretation is although the form is not a regulatory requirement you are making it an official part of your loan documentation, therefore any inaccuracies could, and most likely will, cause you potential problems if the documentation is questioned in court.