Can someone weigh in on the requirement for issuing the Written List of Providers? I have always sent it to the applicant with the Loan Estimate and all other 3 day required disclosures. However, I attended a webinar and they said that the Written List of Providers is to be provided to the applicant separately from the Loan Estimate, within 3 days of the application. I cannot find this in the regulation. Has anyone else heard of this or follow this rule?

Well, that is technically what the rule says:

"(C) Written list of providers. If the consumer is permitted to shop for a settlement service, the creditor shall provide the consumer with a written list identifying available providers of that settlement service and stating that the consumer may choose a different provider for that service. The creditor must identify at least one available provider for each settlement service for which the consumer is permitted to shop. The creditor shall provide this written list of settlement service providers separately from the disclosures required by paragraph (e)(1)(i) of this section but in accordance with the timing requirements in paragraph (e)(1)(iii) of this section."

That said, "separately" doesn't mean it can't be delivered with other disclosures. Did the presenter say it had to be delivered separately, or maybe they were just quoting the rule?



BTW - Welcome to the BOL forums!

Welcome, LMF, to BOL's Forums, informally called "Bankers' Threads."

Thank you! The presenter said that it must be provided separately from the LE.

The presenter was incorrect. Either that or all of us are doing it wrong. Everyone I know puts the LE, SSPL, and other initial docs together to deliver to the applicant within three days.

You could contact the presenter and ask for clarification and regulatory support of their statement too. I have done that when confused after a webinar.

I think "separately" probably means "not attached or stapled to" as easily as it means anything else.

...or not a part of. So it can't be an addendum to the LE. But it definitely can go in the same mailing or be handed to the applicant in a bundle of paperwork in a presentation folder or in a paper clip.

Right...John's addendum comment is more pertinent really, and where i was trying to go.

Exactly. "Provide...separately" (probably) means not on the same document while it could be "delivered" in the same envelope. The rule does say the "creditor shall provide...separately," but it doesn't say you can't "deliver" it together or at the same time.

Also, Truffle makes a good point about contacting the presenter. I can't tell you how many presentations where my mouth has said something different than what my mind intended. If you aren't sure, ask for clarification.