My FI operates in 3 states none of which are Illinois. However, we are closing a mortgage in Illinois. Our practice is for us to prepare the buyers CD. We are getting pushback from this title company. They state that in the state of Illinois the title companies prepare the CD.

Is anyone in Illinois that can either confirm or deny this?

I've researched and come up empty.

(f) Mortgage loans—final disclosures.

(1) Provision of disclosures.

(i) Scope. In a transaction subject to paragraph (e)(1)(i) of this section, the creditor shall provide the consumer with the disclosures required under § 1026.38 reflecting the actual terms of the transaction.

Further (and I'm on a border - we close in Illinois frequently), we always prepare the CD. Maybe this one title company does it but lenders do it everywhere I'm aware of.

Thank you both.

In IL - title companies give us their figures, but we ultimately prepare the CD and deliver to the consumer.

Regardless of who actually prepares the CD, the lender is responsible for what it includes and for timely providing it to the consumer(s). So you can tell that TI company it can go ahead and prepare the disclosure, but you must approve it before it's provided.