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#2164090 - 02/12/18 05:44 PM Title fee changed from LE to CD
Bec Offline
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Bec
Joined: Jul 2010
Posts: 1,115
The Great White North
We originally disclosed a title fee as "Letter Report" and a certain sum on the LE. Turns out that we no longer received a Letter Report and instead got a Lenders Title Insurance. Are we able to disclose the Letter Report on the LE and the Lenders Title Report on the CD seeing as though these fee descriptions are different and could be potentially confusing for the borrower
We were thinking of maybe going the route of disclosing the fee as Title-Letter Report/Lenders Title Report. But to me that is still not the same. Also, that description is too many letters.
Any ideas? Of course the CD has to go out today so if anyone has any quick ideas, it would be much appreciated.
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TRID - TILA/RESPA Integrated Disclosures Rule
#2164095 - 02/12/18 06:21 PM Re: Title fee changed from LE to CD Bec
Truffle Royale Offline

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What do you mean by 'we no longer received'? Did the title company take it upon themselves to issue title work instead of giving you the Letter Report you asked for? If so, they made the mistake, they eat the cost of going over what you requested.

But if you ordered TI when you disclosed you'd be ordering a letter report, my knee jerk reaction is you're curing for the title insurance because bank errors are never valid cc's.

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#2164121 - 02/12/18 07:39 PM Re: Title fee changed from LE to CD Bec
Bec Offline
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Bec
Joined: Jul 2010
Posts: 1,115
The Great White North
It is unknown to me at this time if the lender switched it up and required the lender title insurance or if the title company did the switch. In my opinion I believe that the Lender switched it up so I know that we will be eating the overage for sure.
But my concern is the disclosing of the fees from the LE to the CD. Typically they should match. In this case we have a fee on the LE disclosed as the "Letter Report" and on the CD it will be disclosed as the "Lender Title Insurance". My thought is that it is what it is, the fees are not going to match. I just don't want to have a situation where we didn't disclose the fees correctly on top of having to eat the fee.
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#2164161 - 02/12/18 11:12 PM Re: Title fee changed from LE to CD Bec
Truffle Royale Offline

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You're ok on the naming of the fees because you called/will call them what they each are.
You disclosed a Letter Report on the LE but didn't get one so it just drops off the CD.
You did get title insurance which you didn't put on the LE nor, I'm willing to bet, did you give an SSPL for it either.
So, the borrower didn't shop. The fee listed as Title Insurance goes in Section B and you pay for it.

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