A business decision was made to factor the reissue credit to the lenders title insurance on the Loan Estimate. At times, the invoice from the title company will come back and the lenders title insurance will have increased due to no reissue credit. This is then noted as a valid changed circumstance and no tolerance cure is provided. Is this reasonable? Thank you!

What are you basing the decision on that you are going to be receiving a reissue credit? Is that decision really being made in good faith if it is not happening? Are you allowing the customer to shop for title services, if so, would they not have to pick the previous title company in order to get the reissue credit?

That might work on refi's, but sounds very dangerous for purchases. I would not want that practice in place in my shop. I would stick to the regulation on LTI and OTI. Randy's point regarding good faith is spot on.

I am not sure how a reissue credit would be involved on purchase transaction - but I guess title insurance may work differently in different States.

Yes, this is what I am concerned with. I am not certain that there is any basis on whether a reissue credit will be received or not (especially when the number of years varies by state), it is just automatically assumed it appears. Yes, the applicant is able to shop for title services. It seems like in many instances the applicant does not shop, however.