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#2242303 - 09/10/20 11:48 PM Fee Names
ADN Offline
100 Club
Joined: Mar 2007
Posts: 202
I have lenders using slightly different fee names from the loan estimate to the written providers list. How much variation can they have? (Examination Fee vs Search and Examination Fee)

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TRID - TILA/RESPA Integrated Disclosures Rule
#2242307 - 09/11/20 10:57 AM Re: Fee Names ADN
rlcarey Offline
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Joined: Jul 2001
Posts: 78,618
Galveston, TX
3. Written list of providers. If the creditor permits the consumer to shop for a settlement service it requires, § 1026.19(e)(1)(vi)(C) requires the creditor to provide the consumer with a written list identifying at least one available provider of that service and stating that the consumer may choose a different provider for that service. The settlement service providers identified on the written list required by § 1026.19(e)(1)(vi)(C) must correspond to the required settlement services for which the consumer may shop, disclosed under § 1026.37(f)(3). See form H-27 in appendix H to this part for a model list. Creditors using form H-27 in appendix H properly are deemed to be in compliance with § 1026.19(e)(1)(vi)(C). Creditors may make changes in the format or content of form H-27 in appendix H and be deemed to be in compliance with § 1026.19(e)(1)(vi)(C), so long as the changes do not affect the substance, clarity, or meaningful sequence of the form. An acceptable change to form H-27 in appendix H includes, for example, deleting the column for estimated fee amounts.
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#2242376 - 09/14/20 02:14 PM Re: Fee Names ADN
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,551
Cape Cod
Matched descriptions of services between disclosures has been a major focus of the TRID rules since they were introduced. That's why there is a requirement for listing most of the services in alphabetic order. The thrust behind it all is to ensure that consumers can quickly compare services and amounts.

Of course there is no requirement for similarity in labeling services between creditors, which could facilitate consumer shopping for loans, but I suspect that any such shopping is more about rates and payments and bottom lines rather than lebels.

Speaking of bottom lines, the bottom line here is that failing to match labels for services between the providers list and the LE you leave an opening for criticism and/or citations in an exam.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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