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We have an issue that we’re concerned with.
We have our appraisers selected from a “rolling list” (as all good banks do). One of the appraisers on the list has a DDA with us along with an ownership in our privately held stock. I believe his ownership is no more than 1%.
Also both the attorneys we use to draw up real estate docs have or have had accounts and/or loans with us in the past 12 months. We don’t control or own any of either of these companies and visa versa.
Our procedures and policies are purchased and this is a note provided within the RESPA procedures:
For purposes of this requirement, a relationship exists if (1) the provider is an associate of the Bank, or (2) if within the previous 12 months the provider has maintained an account with the Bank or had a credit arrangement with the Bank, or (3) if the Bank has repeatedly used or required borrowers to use the services of the provider within the last 12 months.
This note references 3500.7(e) – I go to that and I get a discription of the tolerance allowances on the GFE.I’d like to read a little more about this but I’m not finding it anywhere.
Help?? 🙂
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