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#2189529 - 08/17/18 01:26 PM Providers-Reasonable Requirements-Qualifications
Likes to Comply Offline
Diamond Poster
Joined: Nov 2008
Posts: 1,062
In the mountains
19(e)(1)(vi) Shopping for settlement service providers.
1. Permission to shop. Section 1026.19(e)(1)(vi)(A) permits creditors to impose reasonable requirements regarding the qualifications of the provider. For example, the creditor may require that a settlement agent chosen by the consumer must be appropriately licensed in the relevant jurisdiction.

There is a title company in the area whose work is terrible and we really don't want to do business with them. Anything they do, we have to review with a fine tooth comb and have to have them fix numerous things. Would it be reasonable to not do business with someone because they consistently cannot produce error free documents? Would keeping evidence of this be enough to fall under this carve out and not be considered to not have allowed the applicants to shop.

Additionally, we have an attorney of a title company that defaulted on all his loans with us. Do we have to do business with him? Is the reason of the default and foreclosure enough to justify not allowing use of that attorney/title company?
Always learning something new...

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TRID - TILA/RESPA Integrated Disclosures Rule
#2189576 - 08/17/18 03:42 PM Re: Providers-Reasonable Requirements-Qualifications Likes to Comply
burke116 Offline
Platinum Poster
Joined: Jun 2014
Posts: 543
Both of those reasons for not wanting to do business sound reasonable to me.

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#2189633 - 08/17/18 06:43 PM Re: Providers-Reasonable Requirements-Qualifications Likes to Comply
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,793
Cape Cod
Amen to that. You have the final word on whether you'll accept the consumer's choice.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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