Closing Disclosure

Closing Disclosure

Produce a complete five-page Closing Disclosure per CFPB Form H-25 and a compliance review memo. The skill describes the work; specialized math and timing rules live in dedicated sibling skills.

Related skills

• closing-disclosure-tolerance — full TRID tolerance bucket math (zero / 10% cumulative / unlimited), changed-circumstance gating, cure calculation. Defer here for tolerance computations.
• closing-disclosure-timing-reference — 3-business-day waiting period rules, deemed-receipt math, federal-holiday exclusion. Defer here for timing computations.
• cd-tolerance-reference and trid-tolerance — supporting reference material on tolerance edge cases.
• alta-settlement-statement — when the deal also produces an ALTA Settlement Statement (cash, commercial, certain assumptions); reconcile both.
• closing-checklist and ma-closing-checklist — broader pre-closing deliverables; the CD plugs into these.
• loan-modification-agreement — when the matter is a modification rather than a purchase or refinance.
• seller-disclosure, title-commitment — companion documents commonly in scope when reviewing the file.

Checkpoint A: pre-draft intake (mandatory)

Confirm before drafting or reviewing:

1. Role. Lender, settlement agent, borrower's counsel, seller's counsel — the deliverable shape differs by role. Attorney roles produce an issue list and client summary, not a lender-signed CD.
2. Deal type. Purchase / refinance / construction-perm / assumption / modification. TRID coverage and CD requirements vary.
3. State. Pulls in state overlays (transfer taxes, attorney-closing rules, doc stamps). See references/STATE-OVERLAYS.md.
4. Loan Estimate(s). All LEs issued, with issue dates. The most recent valid LE is the comparison baseline.
5. Closing timeline. Rate-lock date and expiration, intended consummation date, CD issue/delivery dates.
6. Source documents. Title commitment, payoff letters, insurance binder, tax bill, HOA estoppel (if applicable), survey (if required).
7. Jurisdiction-specific overlays. State and county-level disclosures, fee structures, and attorney involvement rules.

If any of items 4–6 is unavailable, do not finalize — produce a partial draft with MISSING markers and surface the gaps in the review memo.

The loop

1. Page-by-page data intake. Walk all five pages of Form H-25, populating each field from source documents. Flag missing fields as MISSING. The complete page-by-page checklist is in references/CD-PAGES.md.

2. LE comparison. The most recent valid LE is the baseline. For each fee on the CD, identify the corresponding LE line, classify into the appropriate tolerance bucket, and compute variance. Defer all tolerance math to closing-disclosure-tolerance — its workflow covers fee classification, zero/10%/unlimited testing, changed-circumstance gating, and cure calculation.

A one-paragraph orientation:

3. Re-disclosure triggers. A new 3-business-day waiting period before consummation is required if any of:

• APR increases > 0.125% (fixed-rate) or > 0.25% (ARM)
• Loan product changes (fixed/ARM, term, IO, neg-am)
• Prepayment penalty added

Defer to closing-disclosure-timing-reference for the full business-day counting rules, deemed-receipt computation, and federal-holiday list.

4. State overlays. Apply the state-specific overlay items from references/STATE-OVERLAYS.md. Out-of-table states get a "local-counsel review recommended" note.

5. Cross-document reconciliation. Cash-to-close, payoffs, recording fees, escrows, and APR/TIP each must reconcile against another document in the file. See references/CD-PAGES.md "Cross-document reconciliation" for the specific pairings.

6. Produce deliverables.

• Lender/settlement-agent role: the finalized CD plus a short reviewer's note attaching the LE comparison, tolerance findings, re-disclosure analysis, and any state overlay flags.
• Attorney role: a compliance review memo (no lender-signed CD). The example in assets/examples/cd-review-memo.md shows the shape.

Checkpoint B: post-draft alignment (mandatory)

Before delivering:

1. Tolerance violations: cured (with closing-disclosure-tolerance cure-amount methodology) or explicitly flagged as outstanding for the responsible party?
2. Re-disclosure window: required, and if so, honored? Earliest consummation date stated explicitly?
3. State overlays: applied; any out-of-table state flagged for local-counsel review?
4. Cash-to-close: reconciles against transaction summary, payoffs, and wire instructions?
5. APR/TIP: reconciles against truth-in-lending math?
6. Attorney review: required before signing where role is non-lender?

What this skill does not do

• It does not value the deal or opine on loan terms. Tolerance and timing are mechanical; pricing is between borrower and lender.
• It does not resolve title issues. It identifies them on Page 3 / Page K and routes to title-commitment.
• It does not replace attorney review when the role is borrower's or seller's counsel. Always label the deliverable AI-generated and require sign-off.

Quality checklist

• [ ] All five pages of Form H-25 populated; missing fields explicitly marked MISSING
• [ ] LE comparison baseline is the most recent valid LE
• [ ] Tolerance review run via closing-disclosure-tolerance methodology; cure amount stated where applicable
• [ ] Re-disclosure trigger analyzed; if triggered, earliest consummation date stated
• [ ] State overlay items applied (or out-of-table state flagged)
• [ ] Cash-to-close reconciles to transaction summary and payoffs
• [ ] APR / TIP reconcile to truth-in-lending math
• [ ] Memo labels itself AI-generated and requires attorney/closer review

Troubleshooting

• No prior LE in the file. Cannot complete the LE-CD comparison. Surface as a Critical flag; do not proceed past Step 2 without the LE or a valid changed-circumstance record establishing why no LE exists.
• Multiple LEs and the agent is unsure which is the baseline. The baseline is the most recent LE that was either (a) the original LE for an unchanged product or (b) a revised LE issued under a valid changed-circumstance trigger within the timing window. See closing-disclosure-tolerance for the changed-circumstance gate; if unresolvable from the record, treat the earliest LE as baseline and flag the ambiguity.
• Tolerance violation discovered post-consummation. Cure deadline is 60 calendar days after consummation per 12 CFR 1026.19(f)(2)(v) [VERIFY]. Produce a corrected CD or itemized cure disclosure; document the cure method (refund / escrow application / principal reduction).
• State overlay item references a fee not in the file. Two cases: (a) the fee was waived or doesn't apply — note "N/A" with reason; (b) the fee should appear and doesn't — flag as a Critical-tier missing line and route to settlement agent.
• APR computation in the file does not match recomputation. Most common cause is missing or extra finance charges. Reconcile finance-charge inclusions against 12 CFR 1026.4 [VERIFY]; treat divergence > 0.125% (fixed) or > 0.25% (ARM) as a redisclosure trigger.
• Form H-25 layout differs from a state addendum. Use Form H-25 structure as the federal floor; do not rewrite statutory disclosure text. Append the state addendum without altering H-25 layout. See references/STATE-OVERLAYS.md.

Citations

• 12 CFR 1026.38 — CD form requirements (Form H-25) [VERIFY]
• 12 CFR 1026.19(e)(3) — LE good-faith determination [VERIFY]
• 12 CFR 1026.19(f) — CD timing and delivery [VERIFY]
• 12 CFR 1026.19(f)(2)(v) — Excess refund / cure deadline [VERIFY]
• TILA, RESPA — underlying authority

References

• references/CD-PAGES.md — page-by-page intake checklist
• references/STATE-OVERLAYS.md — state-specific overlay items

Assets

• assets/examples/cd-review-memo.md — finished compliance review memo for a synthetic purchase-money first-lien deal