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#2138474 - 07/17/17 08:07 PM Title Company Error - Lender Credit reduction?
QCL Offline
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QCL
Joined: May 2002
Posts: 6,259
NW IL
We received the title company's quote of fees and disclosed those fees on our loan estimate.

The title company added additional fees that they had "forgotten" - and adjustments were made for this error to the lender credit on the CD to offset this. Today we find out that the "additional fees" were their (title company's) error - a typo if you will - person at the title company seemed to forget the type of loan she was working on and they will not be charged.

Can we now take away the lender credit since those fees from which they resulted will not actually be charged?

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TRID - TILA/RESPA Integrated Disclosures Rule
#2138477 - 07/17/17 08:11 PM Re: Title Company Error - Lender Credit reduction? QCL
rlcarey Offline
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rlcarey
Joined: Jul 2001
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Galveston, TX
How did you initially disclose them - as paid by lender or a general lender credit?
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#2138573 - 07/18/17 04:15 PM Re: Title Company Error - Lender Credit reduction? QCL
Compliance NABW Offline
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Joined: Oct 2015
Posts: 1,669
Slippery slope as the fee always shows up on the LE as a Lender Credit. Perhaps since we are dealing with the CD here, then it is a different situation because it is more specifically detailed.

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#2138618 - 07/18/17 07:08 PM Re: Title Company Error - Lender Credit reduction? QCL
John Burnett Offline
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John Burnett
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Cape Cod
How did you disclose these temporarily-imposed fees on the closing disclosure -- as specific lender credits using the Paid by Others column? If so, prepare another closing disclosure for the closing and simply omit those entries, since the charges won't be imposed.
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#2138636 - 07/18/17 07:58 PM Re: Title Company Error - Lender Credit reduction? John Burnett
QCL Offline
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QCL
Joined: May 2002
Posts: 6,259
NW IL
Originally Posted By John Burnett
How did you disclose these temporarily-imposed fees on the closing disclosure -- as specific lender credits using the Paid by Others column? If so, prepare another closing disclosure for the closing and simply omit those entries, since the charges won't be imposed.


Thanks John. This is what was done. I had to confirm with the underwriter.

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