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#2183987 - 07/03/18 05:02 PM HELOC and differing disbursement recipients
Compliance504 Offline
Platinum Poster
Joined: Dec 2008
Posts: 729
Tennessee
We have a HELOC where the disbursement authorization shows that the disbursement was made to the customer; however in actuality a check was disbursed to the title company....

We're trying to determine what type of error this is? Do any regulations govern this? Or is this a policy/procedure type error?

Any help on what type of error this or any repercussions would be appreciated.....

THANKS!

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Lending Compliance
#2184249 - 07/06/18 08:48 AM Re: HELOC and differing disbursement recipients Compliance504
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,418
Galveston, TX
A disbursement authorization I would assume is more of an internal document than anything else. There is no regulatory requirement to have one. Also could be State law or contract issue possibly.
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#2184718 - 07/10/18 02:59 PM Re: HELOC and differing disbursement recipients Compliance504
Compliance504 Offline
Platinum Poster
Joined: Dec 2008
Posts: 729
Tennessee
Thanks so much, Randy!

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