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We have an affiliate relationship with a title insurance company with less than 1.5% ownership. So, we do not own 25% or more of the company, we do not control in any manner the election of directors and we do not directly or indirectly exercise a controlling influence over the management or policies of the company. However, we do receive some compensation from title insurance sales based upon our percentage of ownership. Currently we include the title insurance fee in the HOEPA fees calculation. With the new TRID rules do we also need to include any title insurance fee (lender’s and owner’s) in the zero tolerance category?
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