It seems that when there is no sale, the lender has the option of using Payments and Payoffs, is that true? I thought it had to be used in order to describe other payments and payoffs specifically enough for the borrower to understand the disbursement.
But, I have a lender questioning this, saying the title company will do a settlement statement (?), so they just normally lump payoffs and payments together and label them, "funds to the title company". They don't even use the payoff table.
Of course this doesn't seem right to me, regardless of whether the title company closes the loan. I told them they needed to follow the example here:
http://files.consumerfinance.gov/f/201403_cfpb_closing-disclosure_cover-H25G.pdf (sample CD - refi, no seller.) Payoffs are clearly labeled. We should not rely on the title company to provide a disclosure not a part of TRID, to satisfy the components of TRID. (That's just crazy talk to me.)
Questioning myself. Can someone please confirm or dispose of my statement above? Thank you.