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#2181424 - 06/12/18 12:22 PM Title Services Disclosed on WPL vs. LE
B.S.50 Offline
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Registered: 06/12/18
Posts: 6
I've gotten some contradictory advice on what services need to be disclosed on our WPL, specifically the format of our title charges. We currently list one title company on our WPL that covers most of our footprint. However, each title company seems to call the fees different names (Lender's endorsement fee v. Endorsement Fee). Do the names and descriptions of the various fees disclosed on the WPL have to match the names and descriptions of the corresponding fees on the LE. For instance, we disclose fees for Title Company A on our WPL. The borrower picks Title Company B. They have similar fees but name them differently. How do they need to match up?

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TRID - TILA/RESPA Integrated Disclosures Rule
#2181427 - 06/12/18 12:24 PM Re: Title Services Disclosed on WPL vs. LE [Re: B.S.50]
Truffle Royale Offline


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Registered: 07/09/03
Posts: 16723
As soon as the borrower choses a company not on your list, it doesn't matter what fees they charge. Naming and cost all fall into Section C - services shopped for with an unlimited tolerance.

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#2181428 - 06/12/18 12:25 PM Re: Title Services Disclosed on WPL vs. LE [Re: B.S.50]
rlcarey Offline
10K Club

Registered: 07/16/01
Posts: 67324
Loc: Galveston, TX
If the customer shopped - they don't have to match up.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2181490 - 06/12/18 03:39 PM Re: Title Services Disclosed on WPL vs. LE [Re: B.S.50]
JPC Offline
Diamond Poster

Registered: 10/22/15
Posts: 1090
You should use the name of the fees from Title Company B or whatever on the CD here, but as far as the initial LE, the point is for Section C to match your Written Provider List. You are only responsible for knowing the services for the written provier you work with and have listed. As others mentioned, once the borrower shops and picks their own company, then the WPL information really no longer comes into play.

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#2182444 - 06/20/18 11:14 AM Re: Title Services Disclosed on WPL vs. LE [Re: B.S.50]
Banker57 Offline
Gold Star

Registered: 07/12/10
Posts: 371
Loc: Minnesota
Does this effect the APR being too high and the finance charge from the LE?

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#2182476 - 06/20/18 01:34 PM Re: Title Services Disclosed on WPL vs. LE [Re: B.S.50]
rlcarey Offline
10K Club

Registered: 07/16/01
Posts: 67324
Loc: Galveston, TX
Not sure what you mean? If the shoppable service fees have to be treated as finance charges and they are higher, then yes it would impact the finance charge and APR - but not sure why that is relevant?
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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