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#2113855 - 01/11/17 12:21 PM "Title" not before a title fee
ComplianceMN Offline

Registered: 05/05/15
Posts: 57
Loc: MN
If our third party processor forgot to put "Title" in front of a title fee on the LE and we missed it before sending it out (customer can shop for this service) can we still charge for this fee? Or does this become a fee that we will need to eat and not charge the customer for? Thanks.

TRID - TILA/RESPA Integrated Disclosures Rule
#2113883 - 01/11/17 01:24 PM Re: "Title" not before a title fee [Re: ComplianceMN]
Truffle Royale Online

10K Club

Registered: 07/09/03
Posts: 15971
What is the fee for?
And if a third party made an error that resulted in eating a fee, I'd be making them pay for it, not me.

#2113910 - 01/11/17 03:18 PM Re: "Title" not before a title fee [Re: ComplianceMN]
raitchjay Offline
Power Poster

Registered: 10/15/09
Posts: 6359
Loc: OK
Not saying it's not important to get such errors corrected, but i wouldn't look at the omission of "title" as meaning the fee must be eaten by the bank. JMO.
I'm fixin' to fix that.

#2113950 - 01/11/17 07:52 PM Re: "Title" not before a title fee [Re: ComplianceMN]
Darth HMDA, CRCM Offline
Platinum Poster

Registered: 12/13/13
Posts: 941
Loc: CA
I'd agree with Raitch - I wouldn't necessarily consider that eating the fee - more of a clerical error that should be fixed on the next disclosure.

You must be really confident in a third party to allow them to produce your disclosures!
The opinions expressed are mine, do not represent the opinions of my employer, and they are not to be taken as legal advice.

#2113976 - 01/12/17 09:28 AM Re: "Title" not before a title fee [Re: ComplianceMN]
Justin C. Offline
Gold Star

Registered: 10/22/15
Posts: 273
Yes, you have a naming convention error, but this is not a tolerance cure issue.