Has anybody came across anything that indicates a CD cannot have any type of markings on it, such as random check marks or even scribbles/doodles for instance? I know the Regulation states the CD must have a specific form and be clear & conspicuous. So, perhaps having such things would violate those sections of the Regulation. The title company seems to have put a couple check marks on the final CD when going over it with the borrower and servicing wants to know if this requires us to redisclose the CD in a "clean" format? Also, they said they have been told you could not write "FINAL" on the final CD. That would seem to be permissible under the section that allows for administrative additions, but perhaps I am missing something. Input is greatly appreciated, as always .

The addition of administrative information is limited to:

(iii) Administrative information. The creditor may insert at the bottom of each page under the disclosures required by this section as illustrated by form H-25 of appendix H to this part, any administrative information, text, or codes that assist in identification of the form or the information disclosed on the form, provided that the space provided on form H-25 for any of the information required by this section is not altered.

Bottom-line: Your settlement agent should not be marking up your CDs.

Yes, but if they did it, do we need to issue a new CD to the borrower?

Bringing this back to life as I had this come up again at a new employer.

What if the settlement agent is acting on our behalf to do the Final CD? Do they "become" the creditor in the Regulation citation mentioned above?

A settlement agent is not the creditor. They are not extending the credit. They are just acting as a closing agent for the bank.