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You are replying to this message: | | Posted by James Powell on 2/10/16 7:01am
Unfortunately, there is another modifier to this section that I think may change your interpretation, Mike.
""Escrow, closing, or settlement services" means the administrative and clerical services required to carry out the terms of contracts affecting real estate. These services include ... [i to xvi]"
The 'include' at the beginning modifies the 'and' at the end to mean that it could be any one of the actions as opposed to all of them.
Definitely need a clarification from the legal authorities for the Commonwealth of Virginia. Considering that someone in the office that will be enforcing the rule is thinking it does apply to NSAs, it is important to get a ruling from the proper authority.
Because of the liabilities and (possible) fines resulting from the implementation of TRID, there is a lot of consideration being given to the definition of 'settlement agent' right now. It has not been specifically defined by the CFPB. |
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