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#185782 - 04/30/04 06:34 PM New title company
Peepers Offline
10K Club
Joined: Jul 2002
Posts: 13,994
We supply an insurance disclosure at application for mortgage loans. We list life & disability, hazard insurance, etc. We go on to state that they’re not deposits, not FDIC insured, etc. We also have the disclosure that we can’t condition the extension of credit on their purchase of an insurance product, etc.

We are in the process of starting a title company subsidiary. We have an ABA disclosure ready to go.

Should we add the title company to our insurance disclosure or would the ABA disclosure be sufficient?

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Lending Compliance
#185783 - 04/30/04 09:45 PM Re: New title company
Anonymous
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#185784 - 04/30/04 10:16 PM Re: New title company
GreatBlue Offline
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GreatBlue
Joined: Feb 2003
Posts: 2,362
Colorado
I don't see any requirement to list types of insurance or names of affiliates in either the credit disclosure or the insurance disclosure.
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Opinions are mine and not necessarily my employer's.

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#185785 - 05/01/04 03:09 AM Re: New title company
Howard Lax Offline
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Howard Lax
Joined: Jan 2002
Posts: 478
Bloomfield Hills, Michigan
Don't forget that the title insurance premium counts toward Section 32 points and fees if the title company is a subsidiary of the lender, or they are both owned by the same holding company.
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Howard A. Lax Lipson, Neilson, et. al. Bloomfield Hills, MI hlax@lipsonneilson.com

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