Take note of key changes described in questions 6 through 9 in the Q&A document
6. When is a consumer permitted to shop for a service?
7. What charges are subject to zero variance?
8. What changes are subject 10% cumulative variance?
A. Charges for creditor required third-party services paid by or imposed on the consumer are grouped together and subject to a 10% cumulative variance. This means the creditor may charge the consumer more than the amount disclosed on the LE for these charges within the variance threshold so long as the sum of the charges added together does not exceed the sum of all such charges disclosed on the Loan Estimate (LE) by more than 10%.
B. Charges for creditor required third-party settlement services where the charge is not paid to the creditor or the creditor’s affiliate.
C. Recording Fees. (Section E)
*The consumer is permitted by the creditor to shop for the required third-party service, and the consumer selects a third-party service provider on the creditor’s written list of service providers (SSPL). Section B of the CD
*Section 1026.19(e)(3)(ii) provides that an estimate of a charge for a third-party service performed by an unaffiliated settlement service provider or a recording fee is in good faith if the aggregate amount of such charges paid by or imposed on the consumer does not exceed the aggregate amount of such charges disclosed under § 1026.19(e)(1)(i) by more than 10 percent, provided that the creditor permits the consumer to shop for the third-party service, consistent with § 1026.19(e)(1)(vi). The Bureau recognizes that some consumers may ask
their creditor or mortgage broker for recommendations when selecting settlement service providers.
9. What charges may change without regard to a variance limitation?