Who Gets A Copy Of The Closing Disclosure?

Although the new TILA-RESPA Integrated Disclosure (TRID) rules started last year, it seems title companies are just recently having issues with who gets a copy of the Closing Disclosure (CD) and ALTA forms in a buyer/seller transaction.  Though TRID doesn't make any changes to the privacy rules that apply to real estate transactions, the CD provides detailed loan information that wasn't found on the old HUD-1 Settlement Statements.  Parties involved in these transactions are under increasingly strict interpretation of The Gramm-Leach-Bliley Act regarding the Privacy of Consumer Financial Information.  As a contract closer that represents various title companies at the signing, I've seen title companies handle copies in many different ways.  However, I believe most companies have now settled in on a standard that seems to make the most sense. 

Buyer - copy of their CD and their ALTA form

Buyer's Realtor - copy of the buyer's ATLA form only

Seller - copy of their ATLA form only

Seller's Realtor - copy of seller's ALTA form only

Buyer's Title Company - original buyer's CD and buyer's ALTA form, copy of seller's ALTA form

Seller's Title Company - original of the seller's ALTA form and copy of the buyer's ALTA form

So the buyer sees all their numbers and terms, the seller sees their numbers, the agents only see the numbers for the client they represent, and the title companies see the numbers pertinent to the transaction.  Note that buyer and seller can share their forms if they choose. 

TILA-RESPA Integrated Disclosure rule implementation

Gramm-Leach-Bliley Act