When I worked at another institution we were written up by examiners for not listing the specific service providers on the GFE as they were the ultimate recipient of the funds. (Example: fllod cert company, appraisal) During a recent review I noticed this same problem here. While I think its possible to list some of the specific providers, I think recent changes in laws have made this unfeasible at times to list the specific appraiser.

We currently use a third party service that chooses our appraisers. Many times we dont know who the appraiser will be in time to list them on the initial GFE and meet the 3 day requirement. The GFE instructions for block 3 appear to be in conflict with todays appraisal practices.

Any thoughts appreciated.

We use, and have always used, generic titles for 3rd party fees at time of GFE. Specfic info is on HUD.

The only list of providers that you current have to provide with a GFE is a list of service providers that the customer may choose from for services that they can obtain from anyone (Block 6) if you want to limit the tolerence to 10%.

I just pulled out the FAQ again and I don't see where it says you have to list the provider on the GFE. The closest I come is on p32 3) referring to governmental loan programs. But the answer there just says '...the settlement service should be disclosed in Block 3'. It says nothing about the provider.

May I ask what cite your examiners used as the basis for writing you up?

We had similar issues on the OLD GFE. Not providing who the service was paid to.

On the New GFE, with our last exam, they made it clear we only need to provide settlement service providers they can choose from. I find no where that lists requires you list the providers they have not choice on.

This is from the GFE instructions on HUD website. It states required and selected. I think that's what the examiner was using. He was probably stretching the interpretation. Thanks for the input.

Block 3, ``Required services that we select.''--In this block, the
loan originator must identify each third party settlement service
required and selected by the loan originator (excluding title services),
along with the estimated price to be paid to the provider of each
service. Examples of such third party settlement services might include
provision of credit reports, appraisals, flood checks, tax services, and
any upfront mortgage insurance premium. The loan originator must
identify the specific required services and provide an estimate of the
price of each service. Loan originators are also required to add the
individual charges disclosed in this block and place that total in the
column of this block. The charge shown in this block is subject to an
overall 10 percent tolerance as described above.

"loan originator must identify each third party settlement service
required "

I believe if you point this out "service" vs. "servicer"...it may clear up the misinterpretation?

Good luck!