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#2138039 - 07/13/17 08:19 PM Multiple Purchase Closing Disclosure
April Parker Offline
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I am sure I know the answer to this question. However, I am looking for a second opinion to verify my thoughts. We have a loan where one borrower is buying 2 separate pieces of property. 2 different purchase prices, 2 different sellers, 2 different sales contracts. Can this be properly disclosed on an LE and CD? Or should it be split into two separate purchase loans?

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TRID - TILA/RESPA Integrated Disclosures Rule
#2138085 - 07/14/17 01:51 PM Re: Multiple Purchase Closing Disclosure April Parker
April Parker Offline
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Any guidance from anyone? Thank you!

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#2138095 - 07/14/17 02:07 PM Re: Multiple Purchase Closing Disclosure April Parker
Truffle Royale Offline

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It's two separate purchases and should be treated as such.

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#2138100 - 07/14/17 02:24 PM Re: Multiple Purchase Closing Disclosure April Parker
RR Joker Offline
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Oh I believe it could be done, however it would require customization ability of the documents in order to produce two distinctly separate seller-only CD's as I don't believe there is a LOS system out there that could/would do that at this point in time. You would really have to know what additions can/cannot be made to the disclosure in order to stay compliant.
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#2138111 - 07/14/17 02:40 PM Re: Multiple Purchase Closing Disclosure April Parker
rlcarey Online
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Check with your settlement agent and see if they can provide separate CD's. The borrower CD would show the combined transaction if done with one loan. I have seen it done.
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#2138113 - 07/14/17 02:44 PM Re: Multiple Purchase Closing Disclosure April Parker
RR Joker Offline
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The only problem I had on the borrower CD was showing two separate deposits [if any] I listed two, but it only totaled one for some reason. The sales prices added up fine. The other thing I didn't really like was it listed the individual seller's together, then on the addendum it listed each with each address which I think would be okay.
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#2138159 - 07/14/17 04:18 PM Re: Multiple Purchase Closing Disclosure April Parker
Truffle Royale Offline

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You're going to have more than just the CD to combine. The note, the mortgage/deed, etc. Are you going to set up a combined escrow? Assigning costs for each property properly (think appraisal, etc.) will be a nightmare. Then you've got the issue of two total strangers (seller A and seller B) being privy to sales numbers of the other. I can think of no good reason to combine these transactions into one and numerous reasons why not to. But that's jmho....

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#2138162 - 07/14/17 04:24 PM Re: Multiple Purchase Closing Disclosure April Parker
rlcarey Online
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The note, the mortgage/deed, etc.

No problem with listing two properties on any deed of trust in most jurisdictions.

Are you going to set up a combined escrow?

Bank option, but would only be required on the property that was a principal dwelling and only under certain conditions.

Assigning costs for each property properly (think appraisal, etc.) will be a nightmare.


Assign them to whom? Either one or the other seller paid for things and the borrower gets a combined disclosure.

Then you've got the issue of two total strangers (seller A and seller B) being privy to sales numbers of the other

Why, if you deliver separate CD to the individual sellers.
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#2138164 - 07/14/17 04:28 PM Re: Multiple Purchase Closing Disclosure April Parker
RR Joker Offline
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Ditto Randy.
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#2138235 - 07/14/17 08:22 PM Re: Multiple Purchase Closing Disclosure April Parker
John Burnett Offline
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It's unusual, but not impossible.
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#2138300 - 07/17/17 01:23 PM Re: Multiple Purchase Closing Disclosure April Parker
April Parker Offline
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Thank you for the guidance. I didn't think it was a good idea, but am hearing an opposite opinion for the officer. Just wanted other's input on the best way to tackle.

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#2279614 - 01/09/23 11:24 PM Re: Multiple Purchase Closing Disclosure April Parker
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How about when a borrower is selling their existing home at the same time as a purchase of a new home? Where do you put the funds from the sale on a Standard CD? It seems like it would go in Section L, potentially as a deposit if the sale funds go into an escrow account first.

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#2279619 - 01/10/23 01:52 PM Re: Multiple Purchase Closing Disclosure April Parker
rlcarey Online
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I would use a separate line, like L - 4 with a proper description. Holding those funds by a third party would like not be part of the purchase contract, so Line 1 is probably not appropriate. But it may depend.

(ii) Any amount that is paid to the seller or held in trust or escrow by an attorney or other party under the terms of the agreement for the sale of the property, labeled “Deposit”;
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#2279644 - 01/10/23 06:07 PM Re: Multiple Purchase Closing Disclosure rlcarey
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Thank you for your input.

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