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#2250062 - 03/03/21 09:34 PM disclosing fees
Compliance Action Subscriber 1226 Offline
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Joined: Sep 2015
Posts: 198
Do we need to disclose a fee for title work in our disclosure of fees or is disclosing the fee before doing the title work sufficient? And do we need to disclose the fee for Canadian checks on our TIS disclosure or is it sufficient to disclose to the customer the fee prior to accepting the check for deposit

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#2250068 - 03/03/21 10:47 PM Re: disclosing fees Compliance Action Subscriber 1226
rlcarey Offline
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rlcarey
Joined: Jul 2001
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Galveston, TX
Disclose where? What title work? Is this like a collection fee that is for special handling or can I just deposit a Canadian item and get charged this fees.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2250089 - 03/04/21 05:55 PM Re: disclosing fees Compliance Action Subscriber 1226
Andy_Z Offline
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On the Net
Is this a car loan or RE, and why are you dealing in a foreign currency? You'll need to be more specific to get a meaningful reply. I hope you can do that.
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#2250096 - 03/04/21 07:41 PM Re: disclosing fees Compliance Action Subscriber 1226
Compliance Action Subscriber 1226 Offline
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Joined: Sep 2015
Posts: 198
Took a Canadian check for deposit and charged him the processing fee that the bank has to pay. Processed like we would have savings bonds, only we don't have a processing fee for savings bonds - the title fee is for automobiles

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#2250098 - 03/04/21 08:15 PM Re: disclosing fees Compliance Action Subscriber 1226
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,219
Galveston, TX
Well, if you have a separate foreign item collection process that is separate from having an account, then it probably would not need to be in your TISA disclosure. No more of a requirement than what it cost to buy a cashier's check.

As far as the title fee - outside of the TILA disclosure for each loan, I am at a loss as to where you would disclose that unless you have some State requirement to publicly disclose loan charges in some manner.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2250099 - 03/04/21 08:21 PM Re: disclosing fees Compliance Action Subscriber 1226
Compliance Action Subscriber 1226 Offline
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Joined: Sep 2015
Posts: 198
OK, I don't need to put these items in any type of disclosure - just advise customer of fees prior to processing their requests - Thank you

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