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#2261707 - 10/27/21 06:47 PM Title Companies with shared ownership
mnbanker09 Offline
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Joined: Jan 2018
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I'm wondering if this situation would be considered as "Services the Customer Did Not Shop For"....

We have Title Company A on our Written List of Providers. Customer decides to use a title company from previous transactions, which is Title Company B. After issuing the closing disclosure, it was discovered that these two title companies are affiliates of each other. Would the title fees need to be listed under Section B - Services the customer Did Not Shop For, or would they remain under Section C?

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#2261715 - 10/27/21 08:35 PM Re: Title Companies with shared ownership mnbanker09
rlcarey Online
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rlcarey
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Galveston, TX
If they are separate companies - whether they are affiliates or not I think is irrelevant from a lender's perspective.
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#2261720 - 10/27/21 08:53 PM Re: Title Companies with shared ownership rlcarey
mnbanker09 Offline
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To confirm, we'd treat this as a Title Company they "did shop for"?

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#2261725 - 10/27/21 09:02 PM Re: Title Companies with shared ownership mnbanker09
rlcarey Online
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rlcarey
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Galveston, TX
Sure - how would you know nor are you required to know whether or not they are affiliates? That is a whole lot different than a borrower going to another office of the same title company.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2261734 - 10/27/21 09:56 PM Re: Title Companies with shared ownership rlcarey
mnbanker09 Offline
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Joined: Jan 2018
Posts: 120
Makes sense. I have since learned a bit more detail on this.

Title Company B told us that the title order would need to go through Title Company A. So, with that, then it sounds like it would need to go under Section B?

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#2261740 - 10/28/21 11:35 AM Re: Title Companies with shared ownership mnbanker09
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,911
Galveston, TX
Totally a business decision on your part. You are not going to find any guidance. Company B must not be much of a title company is all I can say.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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