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#966575 - 05/29/08 10:47 PM Disclosing Service Provider Info - TIL GFE
AuditRocks Offline
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Joined: Dec 2007
Posts: 5
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My bank uses the early TIL and GFE format to provide borrowers updates on proposed mortgage deals. The first version is provided within the 3 days of application with a list of service providers and the statement that "The Bank maintains a lender controlled approved appraiser list. The lender has not yet decided which provider will be selected. The range of costs for the required provider is $250-$1250 depending on the type of appraisal required."

My question is, if we provide subseqent TIL and GFE disclosures, do we need to also provide another list of service providers? In some cases, the new GFE lists the name of the appraiser, but the specific appraiser's information is not provided.

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Lending Compliance
#966651 - 05/30/08 01:13 PM Re: Disclosing Service Provider Info - TIL GFE AuditRocks
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,423
Bloomington, IN
Why are you providing subsequent TIL and GFE?

If you are "amending" the originals then IMO the amendments are to meet the same regulatory requirements as the originals.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#972608 - 06/10/08 07:58 PM Re: Disclosing Service Provider Info - TIL GFE Dan Persfull
AuditRocks Offline
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Joined: Dec 2007
Posts: 5
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That's what I told them, thanks for the corroboration.

Mortgage uses the TIL and GFE as a tool to quote different products for customers or to re-disclose when the rate or amount change.

What does IMO mean?

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#972617 - 06/10/08 08:07 PM Re: Disclosing Service Provider Info - TIL GFE AuditRocks
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 46,423
Bloomington, IN
IMO = In my opinion.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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