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#2206948 - 02/25/19 03:19 AM Alternative CD- Disclosure of Other Credits?
Katherine Offline
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Joined: Aug 2017
Posts: 62
On the alternative form, how should specific other credits be disclosed, specifically, for title insurance, the title insurance company provided a 25% re-insurance credit.

Option 1 - Net the amount. Deduct the reinsurance credit from the title insurance fee and disclose the net amount in Section B (if borrower did not shop).
Option 2 - Disclose the re-insurance credit as a negative amount in Section B on the CD (if borrower did not shop)
Option 3 - Disclose as a negative number on page 3, Payoffs and Payments section.

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TRID - TILA/RESPA Integrated Disclosures Rule
#2207042 - 02/25/19 08:38 PM Re: Alternative CD- Disclosure of Other Credits? Katherine
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 78,971
Galveston, TX
You can list the credit from the title company in the payoffs and payments table:

Paragraph 38(t)(5)(vii)(B).

1. Amounts paid by third parties. Under § 1026.38(t)(5)(vii)(B), the payoffs and payments table itemizes the amounts of payments made at closing to other parties from the credit extended to the consumer or funds provided by the consumer, including designees of the consumer. Designees of the consumer for purposes of § 1026.38(t)(5)(vii)(B) include third parties who provide funds on behalf of the consumer. Such amounts may be disclosed as credits in the payoffs and payments table. Some examples of amounts paid by third parties that may be disclosed as credits on the payoffs and payments table under § 1026.38(t)(5)(vii)(B) include gift funds, grants, proceeds from loans that satisfy the partial exemption criteria in § 1026.3(h), and, on the Closing Disclosure for a simultaneous subordinate financing transaction, contributions from a seller for costs associated with the subordinate financing.
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#2217388 - 07/10/19 09:12 PM Re: Alternative CD- Disclosure of Other Credits? Katherine
mac444 Offline
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Joined: May 2011
Posts: 77
Can this be applied the same for the Loan Estimate when a closing fee is being paid by "Other"? So we would enter the amount as a credit in the payoffs and payments table to offset the cost, then on the Closing Disclosure remove the amount from the payoffs and payments table as the amount would be listed under the Paid by Others column?

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#2217390 - 07/10/19 09:17 PM Re: Alternative CD- Disclosure of Other Credits? Katherine
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 78,971
Galveston, TX
There is no payoffs and payments table on an LE. If you know a third party was paying the fee, it would not go on the LE.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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