And, because that added comment (comment 38(a)(4)-4) was effective 10/10/17 (compliance optional until 10/1/18), you can follow it now. Your "new" information, Nick, is late in coming to you. It reflects TRID 1.0.
Under TRID 2.0, "consumers" who are non-obligors but have a rescission right because of their ownership of the property and their use of the property as their principal residence, still must receive a copy of the closing disclosure three business days before consummation, but they should not be listed as a "borrower" on the closing disclosure.
And welcome to BOL's Discussion Forums!
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8