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.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8