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Must the bank list the seller’s fees on the buyer’s Closing Disclosure for loan transactions that are subject to TRID when the transaction includes a seller and a buyer?

Must the bank list the seller’s fees on the buyer’s Closing Disclosure required under Regulation Z (Truth in Lending Act) for loan transactions that are subject to TRID when the transaction includes a seller and a buyer (consumer)?

Yes. The Consumer Financial Protection Bureau emphasized this with an updated FAQ.

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. (October 2020)

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