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.
Tolerance Categories for New TRID Rules
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?
First published on 11/15/2015