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Written List of Service Providers - Costs of Services

Q: Under the Know Before You Owe/TILA-RESPA Integrated Disclosure Rule ("TRID" or the "Rule") the sample Written List of Service Providers (Model Form H-27) includes a column where the estimated charge for each service is set forth. Is a lender required to include an estimated cost for each service on the Written List of Service Providers?

A: No, TRID does not require a lender to include an estimated cost for each service, nor does it include concrete guidance with regard to contact information for a service provider. Rather, commentary to the Rule indicates that creditors must provide sufficient information, such as the name, address and telephone number, to allow a consumer to contact the provider. §1026.19(e)(1)(vi) only indicates that if a creditor permits a consumer to shop for a settlement service, the creditor must provide the consumer with a written list identifying at least one available provider of that service. It does not require an estimate for each service.

If a lender elects to include a cost estimate it should correspond with the fee set forth on the Loan Estimate. Further, a lender should document its policies and procedures with regard to completion of the Written List of Service Providers to ensure consistency in completion of the document.

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