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September 22
FinCEN's Beneficial Owners Proposal: What It Can Mean for You;
Sonja Kriegsmann and John Burnett

September 23
Bankruptcy 101;
Sam Ott

September 30
Revised Escrow Rules - Review and Update;
Jack Holzknecht and Mary Beth Guard

October 7
CRA - Digging for Credit;
Patricia Cashman

October 8
Applicants and Applications: Knowing the Players and the Rules;
David Dickinson

October 15
MasterCard and Reg E: Basic Debit Card Investigations;
Brian Crow



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#1341765 - 02/11/10 10:34 AM Settlement Service Provider & Appraisal Disclosure
OldSchoolBanker Offline
Platinum Poster

Registered: 05/03/05
Posts: 639
Loc: FL
Seeking clarification on a disclosures we send to clients:

The original Settlement Service Providers where we used to list the appraisers, credit bureaus utilized in the transacton. We used to send it with the GFE. Now with the new Provider list of those the client can shop, do we still have the old list? I think not but am seeking a Guru concurrence.

Thanks
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Old School Banker

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Lending Compliance
#1341778 - 02/11/10 10:40 AM Re: Settlement Service Provider & Appraisal Disclosure [Re: OldSchoolBanker]
Mrs. Rizzo Offline
10K Club

Registered: 03/07/06
Posts: 10385
Loc: Curled up by the fire...
I'm not a guru but if you are allowing the borrowers to shop for those services, you would list them in Block 6 of the GFE and the SSPL has to list at least one servicer for each shoppable service.
If you aren't allowing them to shop, we are putting those fees in Block 3.
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Take responsibility for your life.

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#1341782 - 02/11/10 10:43 AM Re: Settlement Service Provider & Appraisal Disclosure [Re: Mrs. Rizzo]
OldSchoolBanker Offline
Platinum Poster

Registered: 05/03/05
Posts: 639
Loc: FL
Thanks Rizzo, but I am referring to the old Settlement Service Provider list pre 2010 that always listed settlement providers. Has it gone away entirely? Yes, I am aware of the new 2010 Provider List for services they can shop.

regards
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Old School Banker

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#1341788 - 02/11/10 10:47 AM Re: Settlement Service Provider & Appraisal Disclosure [Re: OldSchoolBanker]
Amos Offline
100 Club

Registered: 11/09/04
Posts: 237
Loc: USA
Yes, the "old" provider list is obsolete.

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#1341887 - 02/11/10 12:01 PM Re: Settlement Service Provider & Appraisal Disclosure [Re: Amos]
David Dickinson Offline
10K Club

Registered: 11/28/00
Posts: 13966
Loc: Central City, NE
Just to clarify: There is no longer a "required provider" list. Now there is a "recommended providers" list, but only if you allow the borrower to shop.
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David Dickinson
http://www.bankerscompliance.com

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#1341987 - 02/11/10 01:14 PM Re: Settlement Service Provider & Appraisal Disclosure [Re: David Dickinson]
OldSchoolBanker Offline
Platinum Poster

Registered: 05/03/05
Posts: 639
Loc: FL
Thanks David and Amos. That was thought but I needed a second (and third) opinion.
regards
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Old School Banker

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#1343406 - 02/14/10 04:00 PM Re: Settlement Service Provider & Appraisal Disclosure [Re: OldSchoolBanker]
theloanbug Offline
Gold Star

Registered: 09/10/05
Posts: 370
On the new GFE the only one that shows on our provider is the appraiser. Is this correct? I am so used to my abstracting company, attorney, and appraiser showing on the GFE as providers, but this is no longer how it is. This is correct???

I am just making sure. Thanks for all of your help.

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#1343492 - 02/15/10 05:48 PM Re: Settlement Service Provider & Appraisal Disclosure [Re: theloanbug]
David Dickinson Offline
10K Club

Registered: 11/28/00
Posts: 13966
Loc: Central City, NE
IF you pick the providers (appraisal, credit report, flood determination, for instance) then you don't list these on your Provider List.

IF you allow the borrower to shop for the services, you list companies on your Provider List.

I wouldn't think the appraiser would be on your provider list as you don't let the borrower choose the appraiser.
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David Dickinson
http://www.bankerscompliance.com

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#1518024 - 03/04/11 05:56 PM Re: Settlement Service Provider & Appraisal Disclosure [Re: David Dickinson]
river girl Offline
Platinum Poster

Registered: 11/18/04
Posts: 823
I just looked at one of our initial disclosure packets and apparently we are still using the required provider list. It has the credit reporting agency, the tax certification and the flood ceritifcation companies only.
OH MY!
I looked in RESPA and I see the Affiliated Provider form in Appendix D - I dont' think that is what I need to use - right?
Where do I find the new form for the "Recommended provider's list"? Maybe I use the same template for the old form and just change the wording?
HOW DID I MISS THIS!!!! sick

WOW...pages 14, 15, 16, and 17 of the FAQ. My FAQ are covred in writing except for those pages. I think I need a vaction. AND maybe a new job wink


Edited by river girl (03/04/11 06:05 PM)

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#1518158 - 03/07/11 10:06 AM Re: Settlement Service Provider & Appraisal Disclosure [Re: OldSchoolBanker]
fslic banker Offline
100 Club

Registered: 01/05/11
Posts: 142
Block 6 (Required Services That You Can Shot For) is always blank on our GFEs. We do allow the borrower to shop for Block 4 (Title Services and Lenders Title Insurance) and Block 5 (Owners Title Insurance). Our "List of Providers of Settlement Services" form contains a list of 10 law offices, title insurance companies or abstract offices but there seems to be no differentiation between which companies provide closing services and which may provide owners or lenders title insurance services - all names, addresses and phone numbers are simply listed under the generic heading "Settlement Service Provider". Should this list be differentiated by service offered or is it OK to simply provide an integrated list? Also, we have a column heading on this form for "Estimated Charge for Service" which is never completed. Is this an issue? Thank you.

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