When preparing the Closing Disclosure, should we request to see invoices for the seller portion of fees/expenses for our loan file? We have been taking the fees or expenses straight from the title company CD for the sellers portion, but now are wondering if we should retain them in our loan files and to make sure they are accurate.

I will leave the interpretation of the following up to you.

(ii) Closing disclosures. (A) A creditor shall retain each completed disclosure required under § 1026.19(f)(1)(i) or (f)(4)(i), and all documents related to such disclosures, for five years after consummation, notwithstanding paragraph (ii)(B) of this section.

I think that you also need to evaluate how diligent the title company is in obtaining those seller costs and passing them on to you. Based on what I see in these discussion threads about reluctance of some persons in the settlement process to include seller costs on borrower documents (despite the requirements in §1026.38 to do so), lenders may want to require invoice copies to support the numbers they receive.