Answer:
You are back to the BOL gurus that answered your question in the general forums where you asked the same question.
David Dickinson provided you the proper answer. I suggest that you find a new consultant or have them give you the regulatory basis for their statement, as was suggested in that thread. David already gave you his basis for his opinion and it was straight out of RESPA.
First published on BankersOnline.com 8/22/11