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#2079026 - 05/17/16 06:58 PM Seller's CD-New fee at closing
Compl101TX Offline
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Compl101TX
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W. TX
If a fee charged to the seller (courier fee) is disclosed on the seller's CloD but not on our borrower's CloD, should we issue a revised CloD to our borrower? I say no, since the inaccuracy did not result in a change to an amount paid by the consumer.
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TRID - TILA/RESPA Integrated Disclosures Rule
#2079054 - 05/17/16 08:09 PM Re: Seller's CD-New fee at closing Compl101TX
John Burnett Offline
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John Burnett
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Cape Cod
A courier fee is one that would appear on page 2 of the closing disclosure if properly disclosed. Therefore, it's not one of those seller items that can be omitted from the buyer's disclosure. Therefore --
  • If the error (omission) is caught before the closing is over, there should be a new disclosure provided with the missing cost included. 1026.19(f)(2)(i).
  • If the omission is caught after consummation, there's no need for a revised disclosure because it doesn't change an amount paid by the consumer. 1026.19(f)(2)(iii)
Last edited by John Burnett; 05/17/16 08:13 PM. Reason: added info
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#2079083 - 05/17/16 09:07 PM Re: Seller's CD-New fee at closing Compl101TX
Compl101TX Offline
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Compl101TX
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W. TX
Thank you John.

We did disclose all fees provided by the title company on page two but they added this courier fee without telling us, so it was discovered after closing.
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