I have examiners, they are insisting that I have to have the 3rd party information, name,address, etc as it was on back of the old GFE. I have explained to them that it is not on the form and at this point we don't have to disclose address, phone number. We only have to disclose the name and amount on the 2nd page of the GFE. They are saying I need to put it on a seperate sheet of paper and have the customer sign it. Can anyone shed some light to this. They are saying this is law and I have to disclose it to the customer. If so, why is it not on the new GFE forms? It is NOT on the new GFE. I do have my list of attorneys, pest inspection etc on a seperate sheet of paper that is given to the customer.

I haven't seen anything that requires that the borrower verifying that they received the "shopping list"

and i thought that we were only to provide the type of service and cost estimate.

Hopefully a Guru will come through with some inforamtion.

When were the applications taken and what GFE was issued?

If you issued an old GFE under the old rules then your examiner is correct, other than the acknowledgment part.

If these are GFEs issued after 1/1/10 this examiner needs to study the RESPA revisions as s/he apparently doesn't know what they are talking about.

The old "Preferred Providers List" is a thing of the past after 1/1/10, that section is no longer a part of 3500.7. All you need now is the written list of providers as stated in Appendix C and there is no acknowledgment requirement for this list.

All applications the examiner is talking about is after 1/2010. Thanks, I felt I was correct but you sure can't argue with them!

You are correct - well you can argue with them but that does not do one any good.

I would say: "hmmmm, that is not the way we have interpreted the new regulation, but if you could show us the citation in the new regulations that support your findings, we would be glad to get this oversight corrected as soon as possible."

Good luck with that! We had an issue that we interpreted differently and asked them to show us where it said what they were saying. They couldn't show us but said it was their interpretation so we were wrong.

Well, then its time to make a call to your ombudsman and file your grievance as field examiners are not really allowed to do this anymore. Of course if this is a field examiner, you might want to start with the EIC or the regional supervisor. But, if this is something they say is going to be in the examination report "because they said so" without support - the phone lines would be burning at my bank.

We've been through the field examiner (who by their own admission was not a compliance examiner but a safety & soundness; she was always on the phone trying to get help with the exam), also through the EIC (which was never on site) and a letter to the regional supervisor. All said the same. Their interpretation is...... and so we're wrong. Long story short...the field examiner was here several weeks and now, several months later we're still waiting on an exit meeting. So we're not sure exactly what will be in the report. Worst compliance exam experience I've ever had!

That too is something that should be communicated to your ombudsman. That is what they are there for.....

It amazes me that banks as so gun shy of using the processes that the regulators themselves have set up in order to receive such feedback.