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Itemization of RON-related Fees

1. Can the charges related to the execution of documents through a RON service provider’s platform be separately itemized on the closing statement and/or CD?

Answer:  Generally the answer to this question is “yes” because the remote signing of closing documents would be at the specific request of the buyer or the seller.  However, it would be advisable that you indicate the cost of signing remotely online in any promotional materials that contain closing cost estimates (including a quote to a particular party) so it is clear to anyone who might choose the RON option what the additional cost will be.  Here is a statement from the Department of Financial Services website on this topic:

Title agencies are permitted to charge the third-party fees as separate line  items as long as the consumer has been notified these fees represent responsibilities of the agency, which were contracted to a third party. The consumer must also understand these fees will be charged to them either as part of the closing services fee total, or in addition to the agency's closing services fee. However, in no case should a third-party fee be charged to a consumer in a deceptive or misleading manner.

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