For some of you this TRID Tip won't be of much help because you were previously disclosing Realtor held deposits on the HUD in the same fashion the CFPB is requiring for the Closing Disclosure. For others this will seem regressive and more like a 'blast from the past'. On the Closing Disclosure Realtor commissions are disclosed in full in section H, sorted alphabetically with all of the other fees collected in this section. In the past we have encouraged all of our users to mark Realtor held deposits as "POC" on the financial information screen so that the 700 section of the HUD only reflected the amount of commission disbursed at closing and the system would automatically insert a debit to the seller for the deposit on line 506. With the Closing Disclosure you will want to go back to marking these Realtor held deposits as "Retained (Net Funded)" on the financial information screen. The reason for this is that the CFPB wants the full commission amount disclosed in section H and the only mention of a deposit on the seller side of page 3 is for Excess Deposits, which the system will calculate for you and place on the appropriate line. On the accounting side you will not see any difference as the system will account for the deposit being held by the Realtor and will only disburse any remaining commission.
