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#2299756 - 07/25/24 07:53 PM Service Provider List – Did the Borrower Shop?
m a d_compliance Offline
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Joined: Jul 2024
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At LE it is my understanding of Comment 19(e)(1)(vi)-3, that the fees disclosed in section C. Services You Can Shop For, should match the fees names disclosed on the Service Provider List. What happens if they don’t match?

When a lender goes rouge on the LE, disclosing the borrowers preferred attorney’s fee instead of the fees disclosed on the Service Provider List. Then at closing the borrower wants to use their preferred attorney, what section does the title fees go into? Section B. Services Borrower Did Not Shop For or Section C. Services Borrower Did Shop For?

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#2299761 - 07/25/24 08:18 PM Re: Service Provider List – Did the Borrower Shop? m a d_compliance
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 84,202
Galveston, TX
They put the borrower's preferred attorney on the service providers list? Then on the CD it would go in Section B and be part of the 10% aggregate tolerance.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2299763 - 07/25/24 09:23 PM Re: Service Provider List – Did the Borrower Shop? rlcarey
m a d_compliance Offline
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No they did not update the Service Provider List. So would it go in section C on the CD?

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#2299770 - 07/26/24 10:17 AM Re: Service Provider List – Did the Borrower Shop? m a d_compliance
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 84,202
Galveston, TX
So, you provided a Service Providers List and they selected someone other than who was on your list? They shopped then, did they not? So, it would go in Section C. But if you did not list the fees of your service provider on the original LE, you probably have a good faith effort disclosure violation on the original LE.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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