For banks that have a large footprint and if every loan has a different title company, so how would they be able to know fees upfront?
You will either need to ascertain the fees charged by each of these title companies, you have the option of using "average charges", or the use of estimates in "good faith".
Citation(s): Commentary ¶17(c)(2)(i); Commentary ¶19(f)(3)(ii) and Commentary ¶37–1
Disclaimer: The above information is intended for general information purposes with the goal of assisting Ellie Mae’s customers in complying with the new KBYO regulations. This information is provided as a courtesy to Ellie Mae’s customers and Ellie Mae makes no representation or warranty regarding the accuracy of the information set forth herein, and you may not rely on this information to ensure your company’s compliance with the KBYO regulations. This FAQ should not be construed as legal advice or opinion on any specific facts or circumstances, including the application of the KBYO regulations. You are advised to consult your own compliance staff or attorney regarding your specific residential mortgage lending questions or situation to ensure your compliance with all applicable laws and regulations.
fee disclosure requirements