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#2188934 - 08/13/18 08:37 PM Owner's Title Insurance and LE Redisclosure
SinkCook Offline
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Joined: Sep 2014
Posts: 8
As a business practice we disclose the full, undiscounted OTI on all purchase initial LEs and use a seller credit to offset when it's not a buyer-paid fee. For those that do the same, how do you handle redisclosed LEs? Do you lower the OTI when the invoice shows a lower, discounted amount and/or remove it all together when the invoice leaves it off as well?

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TRID - TILA/RESPA Integrated Disclosures Rule
#2188949 - 08/13/18 09:35 PM Re: Owner's Title Insurance and LE Redisclosure SinkCook
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,371
Galveston, TX
5. Best information reasonably available. Regardless of whether a creditor may use particular disclosures for purposes of determining good faith under § 1026.19(e)(3)(i) and (ii), except as otherwise provided in § 1026.19(e), any disclosures must be based on the best information reasonably available to the creditor at the time they are provided to the consumer. See § 1026.17(c)(2)(i) and comment 17(c)(2)(i)-1. For example, if the creditor issues revised disclosures reflecting a new rate lock extension fee for purposes of determining good faith under § 1026.19(e)(3)(i), other charges unrelated to the rate lock extension must be reflected on the revised disclosures based on the best information reasonably available to the creditor at the time the revised disclosures are provided. Nonetheless, any increases in those other charges unrelated to the rate lock extension may not be used for the purposes of determining good faith under § 1026.19(e)(3).
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