Should it be the exception not the rule to disclose our Closing Disclosure three days prior to closing without commissions and/or accurate title fees and then use the Closing Disclosure provided at closing to add all missing information?

Our business units are disagreeing that the CD 3 days prior to closing needs to be that accurate if the information is not available (they do not get title CDs prior to sending out the three day CD) and they provide an updated CD at closing. They are stating they would not hold a closing up by not sending the 3 day CD on time even if they don't know commissions etc.

I've never had any problem obtaining that info, so my honest opinion is that they have no good excuse for not delivering a reasonably reliable CD. Now having said that...I've yet to have a borrower PAY the commission, so it that's the case, it would not particularly concern me if that wasn't shown until the closing CD.

It's your statement of '...and/or other title fees' that concerns me.
There's no excuse for not having everything four days prior to closing. Commission or title costs aren't going to change.
I'd be leaning on the title companies to get the information to you in a timely manner.
They know better and will normally snap to if you start mentioning taking your business elsewhere.

I agree with Truffle.

As far the CD is concerned, this is the actual closing disclosure.. you should already know what fees are being charge.. and should not be treated like a loan estimate. It should as accurate as possible.

Too many lenders in an effort to be competitive and closing loans as fast as possible are now just putting out CDs the first chance they get. I dont really see it helping much considering how many changes end up getting made afterwards. I see CDs going out as soon as loans are approved. Without invoices, etc. Thats just not right.

The requirement is that you must disclose the actual terms of the transaction on the CD, though you are permitted to provide estimates using the best information reasonably available when the actual terms are not reasonably available to you at the time a disclosure is made. That said, the reasonably available standard requires you to act in "good faith" by exercising due diligence in obtaining the information. If your lenders aren't requesting information from the title company, you are not exercising due diligence in obtaining the information, and therefore, would not be providing the information in "good faith."