Show me in Camp Randy on this one. The bank selected ABC for transaction 2 based on the consumer's earlier use of ABC in transaction 1. It made no pretense of letting the consumer shop the service. It listed it in Section B. There was no need to identify ANY provider for that service on the shopping list.

We have just such a situation with a construction loan request where the LE was issued as "cannot shop". The legal/title section was completed in Sec. B with zero tolerance. No provider list was given.

The LO has advised that the borrower has contacted his legal/title co. and wishes to use them for the closing and not the one used
for the LE. If the customer is saying he has "shopped" for a better deal are we stuck with a zero tolerance. I have read the cite
as posted and the commentary simply does not address this situation per se' but merely says, "... is determined based on all the relevant facts and circumstances." If the borrower is saying, I've looked at your LE and found a better deal do we not give him the benefit of closing with a firm that will save him money, (his firm is an approved closing firm with us). I believe the CD should be completed with the legal/title in Sec. C as he indeed did shop for a better deal. He is saving money on the legal/title closing where there should be no tolerance issue as the costs should be lower anyway. I believe these events are simply not addressed
sufficiently to cover every possible condition that may occur in a real estate transaction. Your responses welcomed.

Well, you are left with a business decision as to how to handle. As you indicate, you are in no-man's-land.

Myself, unless you are doing nothing but a title search through a company of your choice, indicating that you are not going to allow a customer to shop for title services is actually pretty ridiculous on a standard transaction.

I'm curious. Do you allow some to shop and others you don't? I've only worked at two banks since TRID was enacted - one didn't allow shopping and the other one did.

Agreed. This is just another one of those conundrum situations we hear about in the news.