TRID requires settlement agents to provide “the disclosures in 12 CFR § 1026.38 that relate to the seller’s transaction reflecting the actual terms of the seller’s transaction” (12 CFR § 1026.19(f)(4)(i)). “The settlement agent complies…by providing a copy of the Closing Disclosure provided to the consumer, if it also contains the information under § 1026.38 relating to the seller's transaction, or alternatively providing the disclosures under § 1026.38(t)(5)(v) or (vi), as applicable.” (Comment 19(f)(4)(i)-1.)
Providing a HUD-1, ALTA Settlement Statement, or some other “easy” form does not satisfy these TRID requirements. The easiest way to comply is to complete and provide promulgated Form H-25(I) Mortgage Loan Transaction Closing Disclosure - Modification to Closing Disclosure for Disclosure Provided to Seller - Model Form. In the alternative, you have two other options pursuant to the rules outlined above. With the lender’s permission, you can provide the seller with the same form provided to the borrower as long as it includes all the seller information including the specific charges for services and products for which the seller is responsible. Or you can provide a modified or redacted version of the same form after removing all information related to the borrower and lender by following the guidance provided by § 1026.38(t)(v).