Posted By: Carter'sMom
Affiliate Closing Company and Shopping List - 09/15/15 01:58 AM
Think this through with me....
We have chosen to limit the closing companies that we work with (for closing services only). The borrower will still be able to shop for other title services such as lender's and owner's title policies. We have seven companies in one region that have signed our service level agreement. Of those seven, one closing company is an affiliate.
* So as far as the actual closing company - per the regulation, we are not allowing the borrower to shop. However, we are alllowing them to choose from the 7 approved companies in the region. I know that some title companies will be included on our list of services the borrower is allowed to shop for - owner's and lender's title opinion. However, i feel like we need to communicate this list of the 7 allowed in the region for closing services even though we are not technically allowing them to shop. I need to be able to document that we are not "requiring" the use of the affilate and it was actually a choice. I don't love the form H-27C that includes the services the borrower is NOT allowed to shop for but i am thinking this is what we need to use? Thoughts? Also to complicate things, our LOS is not currently offering the H-27C and is not sure when they will offer.
If we tell a borrower that they have to use one of our approved service providers, they will ask for a list. If we provide a list, it must be on an approved form. Am i thinking about this accurately? We seem to have circled around this tree a few times :-)
Thanks!
We have chosen to limit the closing companies that we work with (for closing services only). The borrower will still be able to shop for other title services such as lender's and owner's title policies. We have seven companies in one region that have signed our service level agreement. Of those seven, one closing company is an affiliate.
* So as far as the actual closing company - per the regulation, we are not allowing the borrower to shop. However, we are alllowing them to choose from the 7 approved companies in the region. I know that some title companies will be included on our list of services the borrower is allowed to shop for - owner's and lender's title opinion. However, i feel like we need to communicate this list of the 7 allowed in the region for closing services even though we are not technically allowing them to shop. I need to be able to document that we are not "requiring" the use of the affilate and it was actually a choice. I don't love the form H-27C that includes the services the borrower is NOT allowed to shop for but i am thinking this is what we need to use? Thoughts? Also to complicate things, our LOS is not currently offering the H-27C and is not sure when they will offer.
If we tell a borrower that they have to use one of our approved service providers, they will ask for a list. If we provide a list, it must be on an approved form. Am i thinking about this accurately? We seem to have circled around this tree a few times :-)
Thanks!