Good morning. Wanted to follow up to see if anybody had any thoughts on this and how others may be completing their CD's.
When I looked at one of the completed model forms (H-25B) on the CFPB website, it has all Title related fees paid to the title company. Under section 1026.38(f)(2) Services borrower did not shop for, it mentions to list 'the name of the person ultimately receiving the payment for each such amount.'. Using my same example above, the agent, XYZ Title would get a portion of the title insurance premium as well as the underwriter's portion, First American Title. So based on the sample CFPB form and the explanation under 38(f)(2), if I list just the title company, XYZ Title for all title related fees, I should be compliant, correct?
Opinions/comments are mine and not my employers.