Compliance Docutech

Global Mapping Update: Closing Disclosure Total of Payments for Forgivable Loans with No Payments

Written by Fred Gooch | Oct 22, 2025 5:51:44 PM

ConformX provides an option to not disclose a final payment of the loan amount for forgivable loans with no monthly loan payments. ConformX now provides enhanced handling of the Closing Disclosure Total of Payments for forgivable loans with no monthly loan payments.

Previously, the field “Closing Disclosure Total of Payments” (FI 100473) was set to $0 when both of the following were true:

  • “Forgivable Loan Indicator” (FI 131865) = Yes
  • “Disclose Forgivable Loan Balloon Payment” (FI 131868) = No

 

Background

Under the TRID rule, the Total of Payments disclosed on the Closing Disclosure (Cx18566) must reflect “the total the consumer will have paid after making all payments of principal, interest, mortgage insurance, and loan costs, as scheduled.” [12 CFR § 1026.38(o)(1)]

For forgivable loans where no final payment of the loan amount is disclosed, the total of all consumer-scheduled payments is composed of:

  • Principal: $0
  • Interest: $0
  • Mortgage Insurance: $0
  • Loan Costs: “D. TOTAL LOAN COSTS” (from the Closing Disclosure)

The D. TOTAL LOAN COSTS value is stored in “Fee Section D Borrower (or All) Total” (FI 82332).

Update Details

Instead of being set to $0, “Closing Disclosure Total of Payments” (FI 100473) will now be set to “Fee Section D Borrower (or All) Total” (FI 82332) when:

  • “Forgivable Loan Indicator” = Yes, and
  • “Disclose Forgivable Loan Balloon Payment” = No.

A global standard value field mapping already exists for the analogous field “Total of Payments in 5 Years (Rounded)” (FI 95485), which sets it to “Fee Section D Borrower (or All) Total Rounded” (FI 95489) for these loan types. 

This change is available for testing on Stage and Stage 2 servers and will take effect on October 29, 2025. If you have any questions or concerns about this change, please contact Client Support at 1.800.497.3584. 

T3S-23424

The preceding is for informational purposes only and is not and may not be construed as legal advice. No third-party entity may rely upon anything contained herein when making legal and/or other determinations regarding its practices, and such third-party should consult with an attorney prior to embarking upon any specific course of action.