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If the bank is redisclosing a Loan Estimate under the TRID rule, must the bank resend the written list of service providers with the revised Loan Estimate?

If the bank is redisclosing a Loan Estimate under the TRID rule, must the bank resend the written list of service providers with the revised Loan Estimate?

No, unless the bank has a new service for which the bank allows the customer to shop. Neither Regulation Z (Truth in Lending Act) nor its Commentary address specifically whether a list of service providers should accompany a revised Loan Estimate, but it would seem unnecessary, as the borrower has already received the list. Regulation Z and its Commentary also do not specifically address whether creditors must revise the list of service providers if it changes. However, there are obvious reasons that creditors should, and the small entity guide seems to anticipate providing a revised list if circumstances change and provides options on how a revised list may be provided:

8.7 May the written list of service providers be revised to reflect Loan Estimate revisions?

A creditor may update and re-disclose the written list of service providers to reflect a new service that is added as a result of a changed circumstance or borrower requested change.

When an event that would permit resetting of tolerances under §1026.19(e)(3)(iv) occurs and an additional settlement service is required, the creditor may disclose third-party service providers of that additional service on the written list at the same time as issuing the revised Loan Estimate. If the creditor will permit the consumer to shop for this new service, there are two ways that a creditor may approach adding this new service to the written list.

First, the creditor may include the additional service and provide an updated written list; or

Second, the creditor may provide a written list showing only service providers of the additional service.

See the TRID (TILA-RESPA Integrated Disclosure rule) small entity compliance guide. (October 2019)

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