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#2271298 - 06/07/22 03:02 PM Switch from Third Party to Internal
terpsfan Offline
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Joined: Feb 2007
Posts: 2,059
If a service is switch from third party to internal such as a construction inspection does the tolerance baseline stay the same? I know our system will probably have issue with this as it will think it is a new service but given the service will remain the same it will just go in to a different section it seems like it should not require a cure.

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TRID - TILA/RESPA Integrated Disclosures Rule
#2271303 - 06/07/22 03:21 PM Re: Switch from Third Party to Internal terpsfan
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,393
Galveston, TX
Just realize that there are no provisions in the regulation to switch a disclosed charge from Section B to Section A for tolerance testing, regardless of whether or not the name remains the same. You would have to bet on that logic might prevail with an auditor or examiner.
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#2271404 - 06/08/22 09:33 PM Re: Switch from Third Party to Internal terpsfan
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Yes. We have read lots of stories here about a charge being moved between sections resulting in a system determination that a new charge was added in the section it moved to and the system sees it as a tolerance violation.

The regulation seemingly only recognizes that a service may move from C to B (when the borrower does not shop for a shoppable service).

I do think you have a valid case for moving something from B to A when the bank decides to take a service "in-house" between the LE and the closing. But, as Randy said, you may have to do some convincing of an examiner or auditor.
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