Seller Fees on Buyers CD

What are the requirements for seller fees on the buyers CD? We have a title company that is refusing to provide seller fees because they say they're not required. I thought seller fees were to disclosed in section H of the CD. Am i missing something?

All seller closing costs have to appear on the buyer's CD, regardless of what section they appear - send them this link:


https://www.consumerfinance.gov/pol...sure-faqs/#providing-closing-disclosures

1. If separate Closing Disclosures are provided to the seller and the consumer, does the TRID Rule require that seller-paid Loan Costs and Other Costs be disclosed on page 2 of the consumer’s Closing Disclosure?


Yes, the TRID Rule requires seller-paid Loan Costs and Other Costs to be disclosed on page 2 of the consumer’s Closing Disclosure even if separate Closing Disclosures are provided to the seller and consumer. A creditor does not comply with the TRID Rule if it discloses seller-paid Loan Costs and Other Costs only on page 2 of the Closing Disclosure provided to the seller. 12 CFR § 1026.38(f) and (g); 1026.38(t)(5)(v) and (t)(5)(vi).

See Section 11.7 of the Small Entity Compliance Guide for more information about the modifications allowed when separating the seller and consumer’s Closing Disclosures.

Thank you rlcarey! This is will definitely get the message across!

Two questions:
1) Any chance the title company is talking about the fees shown on page 3 of the CD like loan payoff amounts, etc?
2) is this a one off situation where the seller doesn't want the buyer to see some payoffs OR is it this title company's SOP? 99% of sellers have nothing to hide and likely don't care if the buyer sees their mortgage payoff.

Truffle, it was the seller's title company that was giving us a hard time. The buyer and seller were being represented separately. The buyer title company that was supplying the information to us was having a hard time with the seller title company. Thanks to rlcarey's quick response the seller title company fell in line and gave us what we needed.

After so many years of TRID, the word on this has still not reached all the third parties who can create compliance problems through their ignorance.

Yes John, I agree. I'm very new to TRID so it's extra frustrating trying to fight these situations while I'm still trying to take it all in and learn.

separate title companies??? I've never seen/heard that!

Might be more prevalent in States that do not have a simultaneous issue discount.