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#2100448 - 09/26/16 08:48 PM Charging for completion of the Closing Disclosure
rrush Offline
Joined: Dec 2011
Posts: 74
We have a few title companies that are now charging a "loan closing fee" in addition to the Closing Fee for a purchase transaction. They do not close our loan and do not prepare our Closing Disclosure. When asked what the fee was for, they replied for balancing with you (the bank) and preparing the Closing disclosure. I told them that they were not to prepare our CD and they responded then for balancing with you. My question is 2 part : 1) I know we cannot charge for preparing the CD, can they or can we allow them to? 2) since the fee for this is $350, just for balancing with us, does that appear to be unearned to anyone else? Maybe I am just grumpy but that seems to be a bit of a stretch. Thank you for any light you might be able shed in my darkness

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TRID - TILA/RESPA Integrated Disclosures Rule
#2100467 - 09/26/16 09:44 PM Re: Charging for completion of the Closing Disclosure rrush
Iowa Compliance Gal Offline
Junior Member
Joined: Nov 2015
Posts: 33
Like you we do our own closings and prepare the CloD, a couple of our title companies are charging a "closing fee" it is $295.00 and to the seller on a purchase transaction nothing to the buyer. They do provide us with the seller side closing costs/payoffs so that must be what they are charging for, I have not seen that fee on a refi. Not sure why they think they can charge a ridiculous fee for doing basically nothing in your transaction. Not grumpy I agree a stretch and a way to make a buck since it seems to me they aren't handling as many closings as they did pre TRID they need to make money some how. Just my opinion. :-)

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#2100500 - 09/27/16 01:11 PM Re: Charging for completion of the Closing Disclosure rrush
MonicaMc Offline
100 Club
Joined: Dec 2013
Posts: 236
Land of Oz
We had a title company trying to charge for preparing the Seller CD. We sent them this citation and they removed the fee.

1026.19(f)(5) No fee. No fee may be imposed on any person, as a part of settlement costs or otherwise, by a creditor or by a servicer (as that term is defined under 12 U.S.C. 2605(i)(2)) for the preparation or delivery of the disclosures required under paragraph (f)(1)(i) of this section.

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