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#2262062 - 11/03/21 05:45 PM Title company for CD acquired by SPL Title Co
julesbok Offline
Junior Member
Joined: Mar 2014
Posts: 47
OK
I have searched and not been able to find a thread on this scenario:

We have a branch in CO that listed one title company (#1) on the SPL and their fees on the LE.

The loan is now ready to close and they are using another Title company (#2) for the closing. However, when the closing title company (#2) provided their draft CD with their fees, it was discovered that they are now a division of the Title company (#1) listed on the SPL, which was not known at the time the LE was issued.

Does this now require us to show the title fees in Section B - did not shop and subject to the 10% tolerance since they are a division of Title Company (#1) or would we still show them in Section C, that the customer did shop?

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TRID - TILA/RESPA Integrated Disclosures Rule
#2262068 - 11/03/21 07:05 PM Re: Title company for CD acquired by SPL Title Co julesbok
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 78,958
Galveston, TX
There is no guidance. If you choose to say they are not the same company, then that is a business decision on which you are going to have to be prepared to defend.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2262074 - 11/03/21 07:42 PM Re: Title company for CD acquired by SPL Title Co julesbok
julesbok Offline
Junior Member
Joined: Mar 2014
Posts: 47
OK
Okay. Thanks!

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