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#2198668 - 11/19/18 07:17 PM Previous Service Relied On - Disclose Fee?
Sheldon Hendrix Online
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Sheldon Hendrix
Joined: Jun 2006
Posts: 1,194
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I haven't been able to locate a clear answer to this.

If we are relying on a previous service provided for a property, are we still required to disclose the fee on the LE and CD? This comes up most commonly with previous surveys performed.

I know pre-TRID, there were some nuanced expectations of how this would be required to be disclosed on the GFE and HUD.

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TRID - TILA/RESPA Integrated Disclosures Rule
#2198711 - 11/20/18 09:24 AM Re: Previous Service Relied On - Disclose Fee? Sheldon Hendrix
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
No - it is not a fee (closing cost) for a required service for this specific loan.
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#2198741 - 11/20/18 02:59 PM Re: Previous Service Relied On - Disclose Fee? Sheldon Hendrix
Sheldon Hendrix Online
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Sheldon Hendrix
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That is precisely what I thought. Thanks.

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#2199204 - 11/27/18 08:46 PM Re: Previous Service Relied On - Disclose Fee? Sheldon Hendrix
Vive Accommodare Offline
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Vive Accommodare
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What about the cases where you use a service that would need to be paid for from a previous loan? For example, if you relied on an appraisal for an FHA loan that was transferred and needed to reimburse the original borrower per HUD rules by charging the new borrower. Would you list the service as a fee since there will be a charge and who ultimately gets listed since the original appraiser was already paid?
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#2199214 - 11/27/18 09:27 PM Re: Previous Service Relied On - Disclose Fee? Sheldon Hendrix
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
If is a required fee that they have to pay to get the loan, then it would have to be disclosed. The bank is getting the payment at this point.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2199229 - 11/27/18 11:22 PM Re: Previous Service Relied On - Disclose Fee? Sheldon Hendrix
Vive Accommodare Offline
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Vive Accommodare
Joined: Apr 2013
Posts: 581
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That's what we've been showing, but the original post made me think twice! Thank you!
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"Tact is telling someone to go to [censored] in such a way, they look forward to the trip" Winston Churchill

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