New one for me. Customer asked for a new GFE without Owner's Title quoted, this is a purchase transaction.

Are we allowed to prepare a GFE on a purchase w/o Owner's title?

Does this qualify as a changed circumstance?

Well, rule says for a purchase that it has to be quoted.

What is the borrowers motivation for it being removed?

I say it is a risked based decision on your end if you wish to or not... IMO, if it means losing a deal, I would not fight it and document the file accordingly.

They say they are not going to get it, so they don't want it on the GFE. Course they are not shopping the loan anyway so I do not understand it either.

Thanks.

Anyone else ever run into this? What would you do?

I would agree. Get the customer to sign something demanding it be removed.

Then, ask them to file a complaint with the Bureau for making you put it on there to begin with.

A little bit of knowledge is a dangerous thing.
The knowledge is they know they're not going to get it.
The other little bit of knowledge they obviously don't have is that this is a government regulation they're asking you to break.
I'd probably put it on and give them a cover letter saying 'RESPA requires it but here's what the numbers will look like without it. Hope this satisfies your request.' (of course, you'll write it in a much nicer Southern way. )

I would prefer to put it in a much more formal matter of fact northern way, but I probably would not be allowed to post that veribage here.

Not me, I don't do this ---- wait for it................
It's not in my job description!!!!!


However, I think everything else is.

Thanks,

Owner's title is the best premium you will ever pay. Why would anyone not get it?

I would keep it on the GFE and just remove it at settlement if they choose not to get it. If the customer wants a total of fees without owner's title included you can create a quick Excel sheet to show the total.

fwiw, I agree with KPOC in wondering why anyone would not get owners.

Besides, don't sellers pay for it in the South? They do up here!

Are you sure the buyers understand it? Do they know it's a one-time premium that protects them as long as they own the home?

I agree with Truffle, the borrower needs to negotiate the seller to pay closing costs. That's how we do it too.

The disclosure of the OTI on the GFE for purchase transactions is mandatory by regulation, it is not an option, regardless who is paying for it.

Would you violate the flood rules because the borrower asked you to? Of course not so why would you consider violating the RESPA rules?

Willful violations can carry severe penalties.

Okay, that was my thoughts too. The LO already did one like this. Going forward, no more. It is required to be there, we can give a separate sheet listing the charges as they stand today, but not on a GFE form. (Heck, they might want to sue us for RESPA violations and get a free loan.)

Thanks all.

Good point, SMQ! I don't think I've had a borrower scrutinze a GFE enough to care...

I did have one call, however, recently about intangible taxes.