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#2260899 - 10/07/21 07:39 PM Fee moved from Section H to Section B
mnbanker09 Offline
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Owner's Title Insurance was listed in Section H of the Loan Estimate as optional. (We do not require) A revised LE was produced when the rate was locked, and for some reason the processor moved this fee to Section C. On the Closing Disclosure, it was moved to Section B as they used the title company on our approved list.

Is that appropriate or do we have a tolerance violation?
Last edited by mnbanker09; 10/07/21 07:44 PM.
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TRID - TILA/RESPA Integrated Disclosures Rule
#2260901 - 10/07/21 08:21 PM Re: Fee moved from Section H to Section B mnbanker09
rlcarey Offline
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Galveston, TX
You have a disclosure violation. I do not see it as a tolerance violation.
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#2260904 - 10/07/21 08:40 PM Re: Fee moved from Section H to Section B mnbanker09
Vive Accommodare Offline
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Would that be the same case in a situation where a required fee was placed in the optional section, but then moved to the required/can't shop for section?
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"Tact is telling someone to go to [censored] in such a way, they look forward to the trip" Winston Churchill

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#2260905 - 10/07/21 08:45 PM Re: Fee moved from Section H to Section B mnbanker09
rlcarey Offline
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Galveston, TX
Not in my mind. That is a huge difference. However, if the original loan was being sold in the secondary market - who knows how an investor would see.it. But, if the fee is an optional fees not subject to tolerance testing, I am having a hard time saying that it becomes a tolerance issue simply by skrewing up and placing it into the wrong Section.
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#2260906 - 10/07/21 08:48 PM Re: Fee moved from Section H to Section B mnbanker09
Vive Accommodare Offline
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That aligns with what I was thinking as well. Thanks, RL!
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#2260910 - 10/07/21 09:49 PM Re: Fee moved from Section H to Section B mnbanker09
mnbanker09 Offline
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Joined: Jan 2018
Posts: 128
Thank you for the guidance, appreciate the responses!

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