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#2263848 - 12/21/21 03:16 PM Service Providers List
JobSecurity Online
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Joined: Oct 2009
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I am reviewing a file where a SPL was provided within 3 days of application. There was a change of circumstance after the customer signed the intent to proceed because of the appraisal. For some unknown reason a new SPL was given WITH DIFFERENT PROVIDERS. So I would need to fall back to the original SPL and the original providers for my tolerances correct? The SPL is driven by the application and not by redisclosures right? I am starting to second guess everything I thought I knew frown

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Lending Compliance
#2263849 - 12/21/21 03:23 PM Re: Service Providers List JobSecurity
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
If you provided multiple SPLs with different providers listed, then I would be of the opinion that any providers listed are preferred, regardless of when the SPL was delivered.
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#2263853 - 12/21/21 03:33 PM Re: Service Providers List JobSecurity
JobSecurity Online
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Joined: Oct 2009
Posts: 604
Is providing SPL at different times in the loan process allowed? I did not see that in 1026.19(e).

The customer had already demonstrated they wanted to proceed with the loan. Then we provide another list that contained a different provider. The LE then contained different service titles they could shop for from the original LE.

I appreciate your help Randy. I also like the kinder gentler side of you, it helps on these stressful days.

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#2263857 - 12/21/21 03:49 PM Re: Service Providers List JobSecurity
raitchjay Online
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OK
If your valid CC included a new "can shop for" item, then yes, you need to give a new SPL for that new item.
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#2263860 - 12/21/21 03:53 PM Re: Service Providers List JobSecurity
raitchjay Online
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OK
Oh...i just re-read your post where you mention it was related to the appraisal.....so that wouldn't seem to apply to your scenario.
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#2263862 - 12/21/21 03:54 PM Re: Service Providers List JobSecurity
JobSecurity Online
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Posts: 604
There was no new item(s), just title services. The same as was on the original SPL.

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#2263863 - 12/21/21 03:58 PM Re: Service Providers List JobSecurity
raitchjay Online
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OK
I agree with Randy.....i'd treat any and all providers that were given as preferred providers for this loan.

ETA: i was just trying to answer your question about whether giving a new SPL is ever allowed or required....it is if a new "can shop for" item is created with the valid CC.
Last edited by raitchjay; 12/21/21 03:59 PM.
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I'm fixin' to fix that.

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#2263865 - 12/21/21 04:11 PM Re: Service Providers List JobSecurity
JobSecurity Online
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Joined: Oct 2009
Posts: 604
Thank you raitchjay. I appreciate it.

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