What language is required to print in the ‘Did this Change?’ column when the Seller Credits amount differs between the Loan Estimate column and the Final column for transactions with an Application Received Date on or after 10/1/2018?
When the unrounded Loan Estimate amount differs from the Final column, Yes prints in the Did this change? column. In addition, ‘See Seller-Paid column on page 2 and Seller Credits in Section L’ is the text following the bullet. Regarding the text that prints after the bullet, Regulation Z 1026.38(i)(7)(i) and its commentary provide two different approaches.
One option is to compare the unrounded Generalized Seller Credits from the Loan Estimate to the Generalized Seller Credits from the Closing Disclosure and to also compare the unrounded Specific Seller Credits from the Loan Estimate to the Specific Seller Credits from the Closing Disclosure as in the following comparisons:
- If the only change is in the Generalized Seller Credits, then include See Seller Credits in Section L.
- If the only change is in the Specific Seller Credits, then include See Seller-Paid column on page 2.
- If the change is in both the Generalized Seller Credits and Specific Seller Credits, then include See Seller-Paid column on page 2 and Seller Credits in Section L.