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Tolerance Categories for New TRID Rules

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Question: 
I have a question regarding tolerance categories once the TRID rules go into effect. Here is my potential scenario: Our customer chooses to purchase Owner's Title Insurance. We do not require​ that they do this as a condition of the loan. What if the company they choose is an affiliate of our company. Would this fall into the no limit or zero tolerance category?
Answer: 

Under Regulation Z section 1026.19(e)(3)(iii)(E), charges "paid for third-party services not required by the creditor" fall into the unlimited increase category, even when paid to affiliates of the borrower.

First published on 11/15/2015

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