So, am I to assume that if we have a CD for the loan, we report on it?
Yes.
Page 99 - GIR
1. The amount of total loan costs as disclosed, pursuant to Regulation Z, on Line D
of the Closing Cost Details page of the Closing Disclosure. The Financial Institution
reports the total loan costs if a Closing Disclosure was provided for the Covered Loan.
12 CFR 1003.4(a)(17)(i).
And from 1003.4(a)(17)
2. Purchased loans—applications received prior to the integrated disclosure effective date. For purchased covered loans subject to this reporting requirement for which applications were received by the selling entity prior to the effective date of Regulation Z, 12 CFR 1026.19(f), a financial institution complies with § 1003.4(a)(17)(i) by reporting that the requirement is not applicable to the transaction.
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The opinions expressed are mine and they are not to be taken as legal advice.