Thread Options
#2036898 - 09/02/15 06:11 PM Service Provider List - Company v. Branch Specific
Serendipity Offline
100 Club
Joined: May 2014
Posts: 147
Has anyone heard feedback from a regulator or otherwise, on situations where you list a specific branch of a company (e.g,, Fidelity on 123 Title Street) on the Settlement Service Providers List and the consumer DOES NOT choose that branch, but picks a different branch of the same company (e.g., Fidelity 456 Title Way), if that causes the fee to move from the 10% category (Borrower Can Shop) to the No Tolerance Applied (Borrower Did Shop) category?

Or, since its technically the same company with the same fees, just a different branch, would it be considered that the consumer Did Not Shop and remain subject to the 10% category?


Return to Top
TRID - TILA/RESPA Integrated Disclosures Rule
#2036931 - 09/02/15 07:33 PM Re: Service Provider List - Company v. Branch Specific Serendipity
Dan Persfull Online
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 46,765
Bloomington, IN
If your main branch is located at 123 Bank Street and your outlying branch is located at 123 Branch Street and the customer decided to business at 123 Branch Street instead of 123 Bank Street did the customer choose a differect bank (company) to do business with?
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

Return to Top
#2036933 - 09/02/15 07:36 PM Re: Service Provider List - Company v. Branch Specific Serendipity
Serendipity Offline
100 Club
Joined: May 2014
Posts: 147
Seems obvious to me too, Dan, but curious if there have been any other interpretations out there.

Return to Top
#2037734 - 09/09/15 06:26 PM Re: Service Provider List - Company v. Branch Specific Serendipity
straw Offline
Power Poster
straw
Joined: Nov 2002
Posts: 9,121
Been looking for an answer to this. The issue here in AZ is that some title companies allow their branches to set title fees. So while I refer applicants to a specific branch with certain fees, if they go to another branch of the same company, they may pay a different fee and I am not sure if that would be unlimited tolerance.

Return to Top
#2037829 - 09/10/15 02:55 PM Re: Service Provider List - Company v. Branch Specific Serendipity
Dan Persfull Online
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 46,765
Bloomington, IN
Are these the same title companies or just companies selling title insurance from the same title insurance provider?

I'm not certain how a company located in the same area could/would allow their individual branches to set their own pricing, but in my honest opinion if the title company is ABC Title Limited and they have 10 branches then regardless which branch the borrower chooses ABC Title Limited is the service provider.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

Return to Top