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#2126917 - 04/19/17 12:58 PM Ultimate Recipient
Bville Offline
Diamond Poster
Bville
Joined: May 2001
Posts: 1,282
Out West
On the CD we have to show the 'ultimate recipient' of the fee charged.

How far do we take this? Do we just show who the bank pays, or do we have to know what third parties our third parties use? For example, the bank requires a title search and arranges for a title company to perform the search. The bank pays a fee to the title company for the results of the title search. The title company has contracted with another entity to perform the search and the money the bank pays to the title company is passed (at least in part) to the other entity. Do we show the fee going to the Title Company or do we have to be aware of all the third parties our third parties use?

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TRID - TILA/RESPA Integrated Disclosures Rule
#2126923 - 04/19/17 01:08 PM Re: Ultimate Recipient Bville
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,656
The Swamp
If my servicer has noted who they contracted with for the search, I put the servicername/abstractor name on that line.
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

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#2126924 - 04/19/17 01:09 PM Re: Ultimate Recipient Bville
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,656
The Swamp
[not all of them outsource that, so I have no way to know unless and until they have noted it]
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

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#2130101 - 05/11/17 03:57 PM Re: Ultimate Recipient Bville
Southern Banker Offline
Junior Member
Joined: Sep 2015
Posts: 35
Does this change where the fee is disclosed on the CD since the servicer/abstractor will not be on a service provider list to shop?

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#2130350 - 05/12/17 07:46 PM Re: Ultimate Recipient Bville
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
No. The borrower had the right to shop the service. He selected the provider. The provider determined to outsource to a third party. But the borrower still shopped the service, regardless of the fact that it was outsourced.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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