Dodd Frank- Borrower "Shopping for Services"

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Question:

I have a lender telling me that the borrower was considered to have shopped for services because the provider listed on the Settlement Service Provider List (SSPL) has 3 office locations and the borrower went through a different office location than that disclosed on the SSPL. The lender believes going to a different office address is considered "shopping." I don't agree, but would like clarification on this.

Answer:

by Randy Carey:

You are required to provide contact information for the service provider. If the service provider has multiple locations and the service provider and consumer decide that one of the other locations is more convenient, it is still the same company. They did not shop.

Answer:

by Jim Bedsole:

"Shopping" is when the consumer selects the service provider, not when they select a particular location for the service provider. If they selected the provider on your list, regardless of location, they did not shop. See 1026.19(e)(1)(vi)(A) and commentary as well as 1026.38(f)(3) and commentary.