On the closing disclosure, does the specific loan product have to be disclosed i.e. 7/1 Adjustable Rate or 5/1 Adjustable Rate? We have had two title companies tell us that their software will only allow them to list Adjustable Rate for the product.

Thank you.

Then those title companies have failed to follow the requirements. The requirements as to the Closing Disclosure in section 1026.38(a)(5)(iii) clearly say you provide the Product description as required by 1026.37(a)(10).

Demand that the title company comply with the regulation or you'll have to find another way to get your CloDs prepared, correctly.

Ok, thanks. That's kind of what I thought but wanted to verify.