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#2129307 - 05/04/17 10:08 PM Written Provider List:naming convention same as LE
Compliance Buzz Offline
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Is the Written Provider list required to have the same naming convention as the LE when it comes to title services? It's unclear in the actual regulation, but the sample form in the appendix has them listed that way. CFPB also listed estimates fees and clarified that they were optional in the commentary. Just wanted to see if Title - Settlement had to be that way on the Written List.
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TRID - TILA/RESPA Integrated Disclosures Rule
#2129313 - 05/04/17 10:31 PM Re: Written Provider List:naming convention same as LE Compliance Buzz
rlcarey Offline
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Yes

19(e)(1)(vi) Shopping for settlement service providers.

3. Written list of providers. If the creditor permits the consumer to shop for a settlement service, § 1026.19(e)(1)(vi)(C) requires the creditor to provide the consumer with a written list identifying at least one available provider of that service and stating that the consumer may choose a different provider for that service. The settlement service providers identified on the written list required by § 1026.19(e)(vi)(C) must correspond to the settlement services for which the consumer may shop, disclosed pursuant to § 1026.37(f)(3).
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#2129346 - 05/05/17 01:13 PM Re: Written Provider List:naming convention same as LE Compliance Buzz
Compliance NABW Offline
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Yep, as RL stated. I know there is a gap in this area between practice and the regulation.

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#2129441 - 05/05/17 06:02 PM Re: Written Provider List:naming convention same as LE Compliance Buzz
John Burnett Offline
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This is one of the areas that the Bureau included in its proposed clarifying amendments to the TRID rule. Under the proposal, it's clear there is supposed to be a 1-for-1 match between section C entries and services listed in the providers shopping list.
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#2157720 - 12/19/17 05:15 PM Re: Written Provider List:naming convention same as LE Compliance Buzz
NoJustNo Offline
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So do most of you list "Title Fees" or something similar along with the provider information or do you have to break down each fee (Title - Title Search, Title - Lender's Title Insurance, etc.)?

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#2157728 - 12/19/17 05:28 PM Re: Written Provider List:naming convention same as LE Compliance Buzz
Truffle Royale Offline

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It varies. Some states we work in use title companies to do closing and provide title work which may include searches, etc. In those instances, we match one to one.
Other places only require use of the title company for title insurance so that's all that is on the SSPL.

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#2157756 - 12/19/17 07:37 PM Re: Written Provider List:naming convention same as LE NoJustNo
rlcarey Offline
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Originally Posted By NoJustNo
So do most of you list "Title Fees" or something similar along with the provider information or do you have to break down each fee (Title - Title Search, Title - Lender's Title Insurance, etc.)?


You have to itemize each service, while you could lump the charge for all title endorsements together as they are the same service/product, lumping a title search with lender's title insurance is not going to be correct.
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