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#2294072 - 02/23/24 06:34 PM Required to match the buyer and seller CD's
Compliance Nut Offline
100 Club
Joined: Feb 2016
Posts: 208
I have a scenario I'd like to run by the group:

At the closing table, at consummation; the title company changes the sellers fees.
There is only 1 Seller CD and 1 Buyer CD. The Seller fees at the closing table no longer match the Buyer CD.
There is no Post-Closing CD because the title company made the changes at the closing and the buyer got a copy of the changed seller cd at the closing table.
I’m talking if there is only 1 buyer CD and only 1 seller CD and they don’t match is that a problem? Is it a requirement that the buyer's CD at closing match the seller's CD? If the bank prepares the buyer's CD - not the title company - it seems to me that the bank needs to issue a revised CD and get it to the title company prior to the loan closing. Am I right?

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#2294098 - 02/24/24 01:15 PM Re: Required to match the buyer and seller CD's Compliance Nut
rlcarey Offline
10K Club
Joined: Jul 2001
Posts: 83,605
Galveston, TX
1) Yes, it is a problem.
2) Doesn't your closing instructions indicate that the title company must inform the lender of any changes so that you can re-issue?
3) Since it does not involve borrower paid funds, there is no post-closing CD required, you just have to live with the violations.
The opinions expressed here should not be construed to be those of my employer:

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