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Service Provider List for TRID transactions

11/17/2015

Please be aware that under the new Truth in Lending/RESPA Integrated Disclosure rule (TRID) it may be necessary to revise your service provider list to eliminate references to the old Good Faith Estimate form (GFE) in order to avoid borrower, investor, and/or regulator questions or problems. For example, on transactions subject to the TRID rule, the service provider list should not mention or refer to the good faith estimate or GFE. Also, the items listed on the service provider list should not refer to sections or boxes on the GFE, but should correspond to the fees as shown on the Loan Estimate form (LE).

Additionally, remember that the service provider list must contain a statement stating that the consumer may choose a different provider for that service.  The list may contain a statement stating that the listing of a settlement service provider does not constitute an endorsement of that service provider.  Finally, it is best practice to itemize each fee on the service provider list so that it is consistent with the fees disclosed on the LE.

The TRID rule provides a model written list of providers form. Use of the model form is not required, but creditors using it properly will be deemed to be in compliance with the regulation with regard to that disclosure. Following is a link to that model form on the regulator's website, for your reference:

http://files.consumerfinance.gov/f/201403_cfpb_mortgage-loans-transactions_cover_H27A.pdf