Borrower Name requirement on SSPL

Posted By: Refresher2020

Borrower Name requirement on SSPL - 09/11/20 09:19 PM

Is there a requirement for both borrowers names to appear on the SSPL? We have a custom form and just realized that, on joint applications, only one borrower name is appearing. I can't find any guidance, only that the sample form provided by the CFPB shows both borrower names.
Posted By: Truffle Royale

Re: Borrower Name requirement on SSPL - 09/11/20 09:28 PM

there is no required form or format for the SSPL and no requirement for any name/names to appear on it.
Posted By: Refresher2020

Re: Borrower Name requirement on SSPL - 09/11/20 09:32 PM

Truffle Royale! Thank you!!! - Can I cite that somewhere?
Posted By: rlcarey

Re: Borrower Name requirement on SSPL - 09/12/20 02:23 PM

Since creditors may make changes in the format or content of form H-27, you just have to be prepared to explain why only one borrower is listed. Does listing only one of the borrowers impact the substance, clarity, or meaningful sequence of the form? Why a doc. prep. system would only include one borrower is a little confusing, but I am not sure it has much of an actual impact..

3. Written list of providers. If the creditor permits the consumer to shop for a settlement service it requires, § 1026.19(e)(1)(vi)(C) requires the creditor to provide the consumer with a written list identifying at least one available provider of that service and stating that the consumer may choose a different provider for that service. The settlement service providers identified on the written list required by § 1026.19(e)(1)(vi)(C) must correspond to the required settlement services for which the consumer may shop, disclosed under § 1026.37(f)(3). See form H-27 in appendix H to this part for a model list. Creditors using form H-27 in appendix H properly are deemed to be in compliance with § 1026.19(e)(1)(vi)(C). Creditors may make changes in the format or content of form H-27 in appendix H and be deemed to be in compliance with § 1026.19(e)(1)(vi)(C), so long as the changes do not affect the substance, clarity, or meaningful sequence of the form. An acceptable change to form H-27 in appendix H includes, for example, deleting the column for estimated fee amounts.
Posted By: Refresher2020

Re: Borrower Name requirement on SSPL - 09/13/20 11:00 PM

Thank you rlcarey. I agree, if the model form example has 2 borrowers, I would think, even if not required, it would be beneficial to show both borrower names.