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#2189449 - 08/16/18 07:15 PM CD Section B Charges Provider Unknown
niche girl Offline
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Joined: Jan 2012
Posts: 163
New to the renovation loan market and we are in a quandary. How do you disclose an inspection fee "ultimate provider" on a loan you are selling where you are collecting for inspections to be done after closing but you have no idea who will be providing those inspections because the provider will be selected by the loan purchaser during the renovation process? The customer doesn't shop for the fee so it has to either be in section B or section A. If we list ourselves as the provider since the ultimate provider is unknown I believe we MUST put the fee in section A. However, the primary investor is saying to put it in B and put the provider as "Restoration Escrow", which is of course not a provider, so I do not believe that is compliant. Anyone else have any clarifications or suggestions to offer.
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TRID - TILA/RESPA Integrated Disclosures Rule
#2189480 - 08/16/18 08:35 PM Re: CD Section B Charges Provider Unknown niche girl
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,363
Galveston, TX
You are more technically correct than the investor - but investors make their own rules and they are buying the loan.
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