The Closing Disclosure is only required and designed to be used for transactions which include a mortgage. Commercial transactions are exempt from its required use if the mortgage loan is “primarily” for business, commercial or agricultural purposes.
Although there is no prohibition from using the Closing Disclosure for cash and commercial transactions, you may use any form you wish for those transactions including the custom settlement statements found in DoubleTime®, the new ALTA designed forms, or the original two-page HUD-1(1974 version).