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TRID Tolerance Allowance-Option to Shop

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Question: 
When Title Fees are disclosed on the Loan Estimate in Section C (Services you CAN shop for) but the borrower chooses the vender on our provider list, we know that TRID rules now clarify that these fees must be moved to Section B (services you did not shop for) on the Closing Disclosure. However, TRID also says that we if offer the option to shop and the borrower chooses our providers, there is a 10% tolerance allowance, but in section B, the tolerance is $0. How can we correctly apply the 10% tolerance when the borrower can shop but chooses our provider?
Answer: 

You have to separate the fees that are subject to 0% from those subject to the 10% aggregate tolerance tests regardless of where they appear on the CD.

First published on 05/19/2019

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