The .loc file is not owned by geocaching.com, but rather by Topografix. There would be no problem in offering .loc files.
The cache data in that .loc file however is the property of geocaching.com. Jeremy has come out and stated that while the caches belong to their owners, all the data to be found in his database is his property.
In all likelyhood he would have no problem with it since you are not selling it, and since he himself makes the same data available at no cost you are not cutting into his sales. You might just want to run it past him though.
Note: DO NOT include any Member Only caches in the waypoints.