No it's not a dumb question. If the settlement agent provides the seller closing disclosure as required by 1026.19(f)(4)(i), using a document that's separate from the borrower's disclosure provided by the lender, the settlement agent "shall provide to the creditor (if the creditor is not the settlement agent) a copy of the disclosures provided to the seller under paragraph (f)(4)(i) of this section."
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8