Our vendor is allowing the ability to manually update the Cash to Close on the LE and CD. I'm not sure why yet, however I assume some people will take it to mean we can add in things typically not matching from the LE to the CD, such as aggregate escrows, etc.

Is this strictly prohibited by the rule or can we update it so long as it includes all the items REQUIRED to be in the cash to close calculations? It would still require an explanation to the borrower either way.

May have answered my own question from the CFPB webinar in May:

"Note that the amounts disclosed in the calculating cash to close table are not subject to the analysis under Section 1026.19(e)(3). They are only subject to the basic standard that the creditor make the disclosures based on the best information reasonably available at the time the Loan Estimate is provided under Section 1026.17."

They are letting us override it because the field is in contradiction to the formula in the commentary. Their stance is the regulation and the commentary are contradicting and therefore those of us who wish to "follow" the commentary and calculate it manually can input the correct amount or those who aren't aware can leave it be and have an incorrect disclosure.