According to another BOL thread (Only One Settlement Provider In Town), one of the TRID writers verbally stated any provider on the shopping list gets 10% tolerance, even if there are no alternative providers for the service. So can Iowa banks disclose Title Guaranty as a service borrowers can shop for, even though Iowa Finance Authority is the only provider? Or should Title Guaranty be considered a 0% tolerance service?

We're considering it 0% because we think that's the "intent" of the rule. We should know, and I wouldn't want to argue with an examiner/auditor/judge on that point based on a verbal statement.

So are you putting ITG in Section B and the abstractor and title opinion attorney in Section C as items the borrower can shop for?

Also, do you ever use the option to go with title insurance that is provided for by Iowa State Law when the loan is sold to an investor within 90 days?

That's what we've been doing, TR. ITG in Section B. Abstractor in Section C. We don't allow attorney shopping (too many out there drag their feet on final title opinions), so attorney goes in Section B.
We've never used the title insurance option.

Title Guaranty in B; Title Opinion and Abstracting in C

The answer I got back on the other Q belongs in "Things Not to Say to the Compliance Officer."

Reviving this for your opinions on the following situation.

Title Guaranty put in B. Attorney and Abstractor in C
Servicing Provider List given to borrower shows Attorney, Abstractor AND Iowa Title Guaranty.
Borrower opts to go with Title Insurance.
Closing Disclosure shows title insurance as Title Guaranty but in services shopped for.
Of course title costs went from $90 in C to $460 in shopped for.

I have no idea where to start with this but I'm afraid it may involve a cure....