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Final Closing-Sellers Fees on Buyers CLoD?

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Question: 
I have an investor that is wanting me to issue a final closing disclosure (CloD) with the sellers fees. This would be fine, but they are asking for it to be on my buyers closing disclosure. We normally issue a final CLoD for the buyer and get a CLoD from escrow for the seller. Is my investor correct in asking for the fees to be on my buyers CLoD (fees include Realtor commissions, Owners Title, Transfer Tax, Realtor processing fees, etc.)?
Answer: 

Your investor is correct. While you can deliver a CD to the borrower and not disclose the seller's information in the Summaries of Transactions table, all closing costs on page 2 of the CD have to be disclosed to the borrower, regardless of who pays for those closing costs.

First published on 10/28/2018

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