Is there a home improvement contract involved for $20,000? If there is, it can go in Section H as the CFPB described in my previous post.
If there is no contract, then I would say it belongs in Section K as the title company has suggested:
37(h)(2)(iii) Payoffs and payments.
1. Examples. Examples of the amounts incorporated in the total amount disclosed under § 1026.37(h)(2)(iii) include, but are not limited to: payoffs of existing liens secured by the property identified under § 1026.37(a)(6) such as existing mortgages, deeds of trust, judgments that have attached to the real property, mechanics’ and materialmans’ liens, and local, State and Federal tax liens; payments of unsecured outstanding debts of the consumer; and payments to other third parties for outstanding debts of the consumer (but not for settlement services) as required to be paid as a condition for the extension of credit.
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