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Answers to Questions from CMG 1 on July 10:00 at 1:00

Home Forums Compliance Masters Group (Members Only) Answers to Questions from CMG 1 on July 10:00 at 1:00

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    jholzknecht
    Keymaster

    We received several excellent questions from today’s CMG session. Answers follow the questions below.

    from Vicki to Everyone:
    Will the borrower still be permitted to pick the settlement agent? If so, how could we possibly meet with all the possible service providers and work out provision of the information in a timely manner? For example, if borrower wants to use a service provider that we know is never timely with information can we refuse to accept that agent?
    ANSWER: The borrower will still be able to shop for a settlement agent, if you allow them to shop for a settlement agent. You can require a the borrower to use a particular provider or to choose from a list of approved providers.

    from Linda to Everyone:
    One item that is typically known just prior to closing is the final water/sewer bill. Will this require us to have these figures on the Closing Document 3 days prior to closing?
    ANSWER: Yes, the adjustment for the cost of water unpaid by the seller must be shown.
    • If the amount changes before closing a new disclosure must be provided at or before closing, but a new waiting period is not required.
    • If the amount changes after closing and such inaccuracy results in a change to an amount actually paid by the consumer from that amount disclosed in the closing disclosure, the creditor shall deliver or place in the mail corrected disclosures not later than 30 days after receiving information sufficient to establish that such event has occurred.

    from Vicki to Everyone:
    Regarding delaying settlement — Did any one at the CFPB ever attend a loan closing?!?!?! There are ALWAYS last minute changes. Do we say “Oh, sorry, here is a new Loan Closing Statement, we’ll see you back here in 3 days.”?
    ANSWER: I suspect that someone at the CFPB has attended a closing and yes your explanation, “Oh, sorry, here is a new Loan Closing Statement, we’ll see you back here in 3 days.” would appear appropriate.

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