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#2113855 - 01/11/17 05:21 PM "Title" not before a title fee
ComplianceMN Offline
Member
Joined: May 2015
Posts: 67
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.

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TRID - TILA/RESPA Integrated Disclosures Rule
#2113883 - 01/11/17 06:24 PM Re: "Title" not before a title fee ComplianceMN
Truffle Royale Offline

10K Club
Joined: Jul 2003
Posts: 17,397
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.

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#2113910 - 01/11/17 08:18 PM Re: "Title" not before a title fee ComplianceMN
raitchjay Offline
Power Poster
Joined: Oct 2009
Posts: 9,103
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.
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#2113950 - 01/12/17 12:52 AM Re: "Title" not before a title fee ComplianceMN
JC (Darth HMDA) Offline
Diamond Poster
JC (Darth HMDA)
Joined: Dec 2013
Posts: 1,399
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!
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The opinions expressed are mine, do not represent the opinions of my employer, and they are not to be taken as legal advice.

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#2113976 - 01/12/17 02:28 PM Re: "Title" not before a title fee ComplianceMN
Compliance NABW Offline
Diamond Poster
Joined: Oct 2015
Posts: 1,669
Yes, you have a naming convention error, but this is not a tolerance cure issue.

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