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#2211189 - 04/16/19 02:09 PM
Adding to List of Providers
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If there is an increase in using a title company not on our providers list, at what point would or if they would need to be added to our list? Could this be an auditor/examiner criticism?
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#2211190 - 04/16/19 02:10 PM
Re: Adding to List of Providers
mdog76
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TN
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Is this title company chosen by the borrowers?
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#2211191 - 04/16/19 02:22 PM
Re: Adding to List of Providers
mdog76
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Galveston, TX
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I have the same question. If you have a provider on your written provider list, why would you add another one?
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#2211194 - 04/16/19 02:25 PM
Re: Adding to List of Providers
mdog76
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I am taking the question to be something like this:
Provider A is on the bank's provider list.
85% of the time, borrowers are choosing unlisted Provider B and the OP is wondering if this means that the bank should stop listing Provider A and start listing Provider B. (OP...if that's not what you mean, you can correct me.) FWIW, my answer would still be no.
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#2211197 - 04/16/19 02:26 PM
Re: Adding to List of Providers
mdog76
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They aren't on our list so theoretically yes they are, but they are being used more often here lately.
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#2211198 - 04/16/19 02:30 PM
Re: Adding to List of Providers
mdog76
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Galveston, TX
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It is not a popularity contest. You use the provider for which you are comfortable regarding their fees. Nothing wrong with gaming the system a little either. As long as your service provider is available to the consumers to provide the services, having them pick someone not on your list gives you an unlimited tolerance.
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#2211211 - 04/16/19 03:51 PM
Re: Adding to List of Providers
mdog76
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In the spirit of "gaming the system" and for arguments sake, what would stop a bank from listing just one title company and letting the rest of the title companies in the area be unlimited therefore eliminating COC's for title fees or lender credits because the title company went up?
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#2211213 - 04/16/19 03:55 PM
Re: Adding to List of Providers
mdog76
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You are re-issuing LE's because the borrower doesn't choose your title provider? There's no reason to do that (in fact, there's no valid changed circumstance occurring...so you can't do that).
What you say though is exactly what banks do (without problem): List a provider you are comfortable with and if they choose a different one, head to unlimited tolerance land and simply show the title fees as "borrower shopped for" items on the CD.
Last edited by raitchjay; 04/16/19 03:56 PM.
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#2211214 - 04/16/19 03:58 PM
Re: Adding to List of Providers
mdog76
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Sorry if my question wasn't clear, but we don't do that. What I meant was eliminating COC's because title fees changed/increased or lender credits because title fees increased. This is just a hypothetical question at this point.
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#2211215 - 04/16/19 04:03 PM
Re: Adding to List of Providers
mdog76
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Cape Cod
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Clarification -- You can't issue a revised LE to reset estimates when there's no changed circumstance or other triggering event. That's true. But you can issue an informational LE with updated info at any time before the CloD is issued in the spirit of keeping the borrower current on costs and anticipated cash due at/from closing. But too many LEs is never a good idea and it's frowned on by the CFPB because it can result in info overload and consumer confusion.
So most banks issue the initial LE and only those revised LEs required to use changed circumstances and similar trigger events to adjust cost estimate bases and avoid tolerance violations. Some even avoid revised LEs for changed circumstances unless the potential tolerance violation is more than a significant amount.
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#2211220 - 04/16/19 04:25 PM
Re: Adding to List of Providers
mdog76
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mdog....if title fees from Provider B who wasn't on your provider list increase--it's a non-event, because it's unlimited tolerance. Or am i still not understanding what you're asking?
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#2211243 - 04/16/19 05:59 PM
Re: Adding to List of Providers
mdog76
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Thanks for the input everyone. This was just a hypothetical that came to me. We actually have about 5 or 6 title companies on our provider list. If I was a title company, I wouldn't want to be a banks list.
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#2211244 - 04/16/19 06:02 PM
Re: Adding to List of Providers
mdog76
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Why not? What skin is it off the title company's back whether they're the provider on your list? I would think if anything, it might be appreciated because at least vaguely, the bank seems to be recommending that title company. At least in my little corner of the world, where we have 2 main title companies in town, the 1 that isn't in our list would probably be huffy if they knew that (they may know it already....not sure).
Last edited by raitchjay; 04/16/19 06:03 PM.
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#2211245 - 04/16/19 06:09 PM
Re: Adding to List of Providers
mdog76
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(I didn't mean that to sound short in any way...i'm just truly curious as to why you think that.)
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#2211249 - 04/16/19 06:22 PM
Re: Adding to List of Providers
mdog76
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No problem. If I was a title company and knew how the tolerances worked, I'd rather be left off the provider list and be able to be subject to unlimited tolerance (within reason). But if in a place with 2 or 3 title companies, I can see where huffy attitudes could arise by not being on a banks list. We are in a heavy tourist area with cabins everywhere (Sevier County, TN) and there are a lot of title companies to choose from.
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#2211253 - 04/16/19 06:28 PM
Re: Adding to List of Providers
mdog76
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Have to be a pretty shady title company to start basing prices on that........think they could get themselves in some pretty deep hot water if they tried that.
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#2211267 - 04/16/19 07:12 PM
Re: Adding to List of Providers
mdog76
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We actually have about 5 or 6 title companies on our provider list. Wow - how in the world do you quote the fees correctly in Section C if you have six different answers for a specific fee?
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#2211333 - 04/17/19 02:17 PM
Re: Adding to List of Providers
mdog76
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The Swamp
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I'm in small markets, but have historically only listed one provider per market. They all know how this works smile
Last edited by RR Joker; 04/17/19 02:18 PM.
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#2211357 - 04/17/19 03:40 PM
Re: Adding to List of Providers
mdog76
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Cape Cod
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A title company is going to charge what it is going to charge whether it's on your list or not. They know they will be paid, and they don't really care whether the money is from the borrower's pocket or the bank's.
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