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#2182798 - 06/22/18 05:35 PM Fees on subsequent LE's are lower than on first
ns Offline
100 Club
Joined: Aug 2016
Posts: 120
If a title fee (for example) is lower on a subsequent LE, which was provided not due to a changed circumstance, should we use the higher fee from the first LE to calculate tolerances or should we use the lower fee from the informational LE to calculate tolerances? We feel it could appear we are padding tolerances if we use the higher amount from the first. We understand when fees increase we have to utilize the higher fee from the first LE but we don't feel the reg addresses if the fee decreases. Please advise. Thanks!

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#2182802 - 06/22/18 05:59 PM Re: Fees on subsequent LE's are lower than on first ns
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
An informational LE is just that. It does not change your tolerance baselines. Only a valid changed circumstance can raise your baselines from the initial LE. They will never be lower. If you have a pattern or practice of your initial fees being substantially higher than actuals, then your initial LEs are not issued in good faith.
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