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#2220452 - 08/27/19 01:10 PM Providers List
mdog76 Offline
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Are banks supposed to send out a new service providers list with a revised LE and Changed Circumstance?

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TRID - TILA/RESPA Integrated Disclosures Rule
#2220453 - 08/27/19 01:25 PM Re: Providers List mdog76
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 78,967
Galveston, TX
If you added services to Section C - yes. Otherwise - no need.
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#2220454 - 08/27/19 01:27 PM Re: Providers List mdog76
mdog76 Offline
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Posts: 645
We saw on another forum that other banks were advised to and were dinged for it. But like you we didn't see the need for it either, unless something was added.

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#2220456 - 08/27/19 02:09 PM Re: Providers List mdog76
rlcarey Online
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rlcarey
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Galveston, TX
Then they were dinged for no reason.

As discussed above, some commenters asked the Bureau to clarify whether a creditor may issue a revised written list of providers. As Bureau staff noted in an informal webinar, a revised written list of providers may be issued when a settlement service is added as a result of a reason provided for under § 1026.19(e)(3)(iv). Whether or not a creditor issues a revised written list of providers, in accordance with final comment 19(e)(3)(ii)-6, if the creditor permits the consumer to shop consistent with § 1026.19(e)(1)(vi)(A), good faith is determined under § 1026.19(e)(3)(ii), unless the settlement service provider is the creditor or an affiliate of the creditor, in which case good faith is determined under § 1026.19(e)(3)(i). Whether the creditor permits the consumer to shop consistent with § 1026.19(e)(1)(vi)(A) is determined based on all the relevant facts and circumstances.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2226153 - 11/22/19 04:31 AM Re: Providers List mdog76
Hawk Offline
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Joined: Jan 2019
Posts: 56
The service provider list is for the fees quoted on the initial loan estimate, which remain on that loan estimate until the CD. Why would you need to provide a provider list with every LE. Thats silly. Unless a fee were added, like stated above.

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#2226154 - 11/22/19 04:32 AM Re: Providers List mdog76
Hawk Offline
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Joined: Jan 2019
Posts: 56
Also, the service provider listed needs to be dated within 3 days of the application date. Issueing subsequent ones would make no sense and be out of compliance unless their for informative purposes only.

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