Hmmm, I was told that we were told that we were required to utilize the HUD1-A to comply with Reg X (whether it was an examiner or a consultant, I am not sure, but will look into it).
We have done it for at least the 4 1/2 yrs since I have been here and it seems odd to me that neither our examiners or consultants expressed a concern about the fact that we were doing it. It was probably stated that it was our bank policy to do it that way across the board. If so, then they would have probably nailed us on it if we forgot to do it on one.
Meanwhile, I see what you are saying Dan, if it's not required, don't mess with it. If a borrower requests it, in what fashion do you provide the information?