The lenders at the corporate level have 3rd party vendor management oversight compliance concerns so presumably the title company they selected passed their compliance and audit requirements to be on their recommended list. Section 1026.19)(e)(1)(vi)(A) permits creditors to impose reasonable requirements regarding the qualifications of the provider (i.e. title company). For example, the creditor may require that a settlement agent chosen by the consumer must have a SSAE 16 SOC 1 Type 1 Certification from a qualified CPA firm. If a creditor does not permit a consumer to shop for purposes of 1026.19(e)(1)(vi) if the creditor requires the consumer to choose a provider from a list provided by the creditor. Section 1026.19(e)(1)(vi)(C) provides that the creditor must identify settlement service providers that are available to the consumer. A creditor does not comply with the identification requirement in § 1026.19(e)(1)(vi)(C) unless it provides sufficient information to allow the consumer to contact the provider, such as the name under which the provider does business and the provider’s address and telephone number. Similarly, a creditor does not comply with the availability requirement in § 1026.19(e)(1)(vi)(C) if it provides a written list consisting of only settlement service providers that are no longer in business or that do not provide services where the consumer or property is located.
https://www.legacy.atssecured.com/wp-content/uploads/2016/04/ats_secured_logo_trans_2016-2-300x138.png 0 0 Emily Smith https://www.legacy.atssecured.com/wp-content/uploads/2016/04/ats_secured_logo_trans_2016-2-300x138.png Emily Smith2016-07-11 13:54:152016-07-11 13:54:15Why can major lenders recommend at a corporate level, what title company to use, but loan officers can’t suggest different companies to borrowers?