As part of our efforts to assist clients with producing compliant Integrated Disclosure documents, we are updating four Data Integrity Checks to flag potential data problems on the Calculating Cash to Close table on the Closing Disclosure (our Cx18566 and Cx18991 – Spanish). The Data Integrity Checks are specifically looking at the Total Closing Costs (J), Down Payment/Funds from Borrower, Seller Credits, and Adjustments and Other Credits. The updated Warnings each read as follows:
Total Closing Costs (J)
On the Closing Disclosure, the amounts disclosed in the “Loan Estimate” and “Final” columns of the “Total Closing Costs (J)” row of the “Calculating Cash to Close” table are different, but there are no changes to the charges disclosed in Sections D and I which would cause these differences (see 12 CFR § 1026.38[i][1][iii][A][2]). Please review your data for any errors.
Down Payment/Funds from Borrower
On the Closing Disclosure, the amounts disclosed in the “Down Payment/Funds from Borrower” row of the “Calculating Cash to Close” table are different, but there are no changes to the charges disclosed in Sections K and L which would cause these differences (see 12 CFR § 1026.38[i][4][iii][A]). Please review your data for any errors.
Seller Credits
On the Closing Disclosure, the amounts disclosed in the “Seller Credits” row of the “Calculating Cash to Close” table are different, but there are no changes to the charges disclosed in Section L (Line L.05) and the “Seller-Paid” column of the “Closing Cost Details” tables which would cause these differences (see 12 CFR § 1026.38[i][7][iii][A]). Please review your data for any errors.
Adjustments and Other Credits
On the Closing Disclosure, the amounts disclosed in the “Adjustments and Other Credits” row of the “Calculating Cash to Close” table are different, but there are no changes to the charges disclosed in Sections K and L which would cause these differences (see 12 CFR § 1026.38[i][8][iii][A]). Please review your data for any errors.
For each of these Warnings, we are comparing the current components of these amounts against the last disclosed components of the previously disclosed amounts. If the current and previously disclosed amounts are different, but the components of those amounts are not different from the previously disclosed components of said amounts, then the Warnings will fire. For example, the Total Closing Costs (J) is calculated by summing the amounts in Section D, Section I, and the Lender Credits in Section J. If the Total Closing Costs (J) in the Loan Estimate column and the Final column on the Closing Disclosure do not match, but all the items in Section D, Section I, and Lender Credits do match the previously disclosed amounts in Section D, Section I, and Lender Credits, then the Total Closing Costs (J) Warning text will be triggered.
These changes will be in effect on August 17, 2018. Please note that client-specific customizations may impact the announced standard modifications. If you have any questions or concerns about these changes, please contact Client Support at 1.800.497.3584.
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