For all the charges listed starting with "Title - xxx" - do we alphabetize what comes after the hyphen? Our software does this, but the settlement agent doesn't have them listed this way. I'm assuming we would want them to list in the same order we have ours.

Yes, they need to be alphabetized after the hyphen.

I've heard a story that occasionally when a charge is hand-typed, a space will be included/omitted on one side of a hyphen or another, causing the software to alphabetize differently from what we think it should. If they're having issues with that, maybe run this suggestion by them .

Thanks, WSB!

settlement agents....... sigh

good luck!

If you are issuing the Closing Disclosure, what difference does the order of the charges on the settlement agent's invoice make? You control the order and the description on the CloD.

We are only issuing our customer's CD and the title company is issuing the Seller's CD.....so if we have listed the seller's fees on our buyers disclosure in the proper order, we don't care how the title company puts their fees on their seller disclosure? That would make it easier for us.

Correct. Just be sure you get the seller's fees that you need for completing page 2, including his/her real estate agent fees.

Yay!! Thanks, John.

Bringing this thread back from the dead....

On one of our recent QC audits, we are being cited for incorrect alphabetizing in Section C.

They are saying that:

Title - Closing Protection Letter
goes AFTER
Title - Closing/Escrow Fee
Because "P" goes after "F"

Our LOS is alphabetizing these for us, and they are also hardcoded fee names. Our LOS has said that in their coding, they recognize plain space value as greater than the extra non-alpha special character.

Thoughts?

A "/" between Closing/Escrow would be treated basically as a space using most alphabetical standards. Since a specific alphabetical standard is not referenced in the regulation - what are they basing their citation on??

That's a good question. When I enter the same fees into a Word document and alphabetize them, it puts the "Title - Closing Protection Letter" before the "Title - Closing/Escrow Fee" - which is how we have it. Looks like ASCII (American Standard Code for Information Interchange) has the "space" preceding everything and a "slash" as the last character before numerals.

Sometimes auditors and examiners can just get too focused on minutiae. Since the reg doesn't say what alphabetization standard to use, I think the criticism here is unreasonable. And, BTW, if the same costs were listed in the same way on both the LE and the CloD, they should appear in the same order on both (unless you're creating them one two different systems).