Would it be required to list a service twice on an LE where we ultimately had to use two vendors for the same service? Borrower switched jobs in the middle of the loan and our VOE vendor was disclosed with upfront disclosures, but when they switched employers they use a different vendor and we had to use the vendor they use for re-verification.

I'm confused....providers don't show up on the LE. Are you talking about on the CD?

in our LOS we have to break down who the service is paid to and yes, then ultimately on the CD we'd need to show the payees, but for the LE do we need to show two VOE amounts since it's from two separate providers?

Did you have a valid CC and re-issue the LE?

If so, i think i'd show it twice, since you need things to match up from LE to CD and you'll have separate entries on the CD side....since i'm not aware that you can show one service and two payees on the same line of the CD.

It's an interesting scenario......and i don't have time to research it at the moment.....but my gut tells me that ^^^^

It looks like they had a valid CC and re-issued the LE, but increase the fee instead of placing it on a separate line item.

I'm just guessing that your LOS's tolerance tool might have to be manipulated some....because again, it doesn't seem kosher to me to list one fee and 2 payees on one line of the CD...so when you break it out in 2 on the CD, you might have to finagle your tolerance tool.

But i don't see the LE showing an increase in the fee (instead of adding a 2nd VOE fee) as a huge error.....if it was here at my shop, i definitely wouldn't cure for the 2nd VOE fee, if we handled the timing of the re-issued LE correctly.

That's kind of what we were thinking, but our compliance tool does give us a fail due to the new fee the borrower can't shop for

On a portfolio loan, you should be able to explain this. On a secondary market loan, you are going to be at the mercy of the investor.