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#2133579 - 06/08/17 06:55 PM 10% Tolerance Charges
mdog76 Offline
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Joined: Jan 2007
Posts: 645
When the seller pays portions of the loan costs subject to 10% tolerance, is the bank only concerned with what amount the borrower paid? For example; Doc prep on LE: $85; Doc prep on CD: $155 borrower paid and $185 seller paid for a total of $340. Are we concerned with the $155 or the entire $340?

Thank you.

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TRID - TILA/RESPA Integrated Disclosures Rule
#2133583 - 06/08/17 07:03 PM Re: 10% Tolerance Charges mdog76
mdog76 Offline
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Joined: Jan 2007
Posts: 645
I'm pretty sure we might have tolerance violation here cause there are three other charges similar to the one above, just trying to determine how much of a violation we might be dealing with.

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#2133615 - 06/08/17 08:18 PM Re: 10% Tolerance Charges mdog76
PCBDebbie, CRCM Offline
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Only borrower paid charges would be subject to the tolerance calculation. Also keep in mind the 10% tolerance is an aggregate total.
Last edited by PCBDebbie, CRCM; 06/08/17 08:19 PM.
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#2133617 - 06/08/17 08:24 PM Re: 10% Tolerance Charges mdog76
mdog76 Offline
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Joined: Jan 2007
Posts: 645
The title company increased charges on us for some reason and I think we are out of tolerance on this one.

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#2133621 - 06/08/17 08:26 PM Re: 10% Tolerance Charges mdog76
PCBDebbie, CRCM Offline
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Posts: 155
Was it a title company that was listed on your SPL? I would be looking into this further to see why they increased the fees if they are on your list.

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#2133629 - 06/08/17 08:50 PM Re: 10% Tolerance Charges mdog76
raitchjay Offline
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Joined: Oct 2009
Posts: 8,874
OK
And if they want to continue being on your list, they might want to not do so again without prior notification.
_________________________
I'm fixin' to fix that.

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#2133665 - 06/09/17 12:18 PM Re: 10% Tolerance Charges raitchjay
PCBDebbie, CRCM Offline
100 Club
Joined: Aug 2015
Posts: 155
agreed

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#2133692 - 06/09/17 02:50 PM Re: 10% Tolerance Charges mdog76
Truffle Royale Offline

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Posts: 17,359
I wouldn't be taking the jacked up fees on this loan if the title company is on your list.
Unless there was a valid CC that you knew about but didn't redisclose on to capture any additional title costs, I'd be telling them in no uncertain terms that they can't change the costs now. They know the TRID implications and should have warned you earlier.

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