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#2194928 - 10/09/18 02:25 PM invoices
ADN Offline
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Registered: 03/15/07
Posts: 146
When preparing the Closing Disclosure, should we request to see invoices for the seller portion of fees/expenses for our loan file? We have been taking the fees or expenses straight from the title company CD for the sellers portion, but now are wondering if we should retain them in our loan files and to make sure they are accurate.

TRID - TILA/RESPA Integrated Disclosures Rule
#2194931 - 10/09/18 02:43 PM Re: invoices [Re: ADN]
rlcarey Online
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Registered: 07/16/01
Posts: 68944
Loc: Galveston, TX
I will leave the interpretation of the following up to you.

(ii) Closing disclosures. (A) A creditor shall retain each completed disclosure required under § 1026.19(f)(1)(i) or (f)(4)(i), and all documents related to such disclosures, for five years after consummation, notwithstanding paragraph (ii)(B) of this section.
The opinions expressed here should not be construed to be those of my employer:

#2194937 - 10/09/18 02:57 PM Re: invoices [Re: ADN]
John Burnett Offline

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Registered: 10/27/00
Posts: 37497
Loc: Cape Cod
I think that you also need to evaluate how diligent the title company is in obtaining those seller costs and passing them on to you. Based on what I see in these discussion threads about reluctance of some persons in the settlement process to include seller costs on borrower documents (despite the requirements in §1026.38 to do so), lenders may want to require invoice copies to support the numbers they receive.
John S. Burnett
Professional Compliance Nerd since 1976
Bankers' Threads User #8