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July 29
W-9, W-8BEN and W-8 BENE: IRS issues new forms and new rules;
Deborah Crawford

July 31
ACH Security Framework Rule - Small Rule, Big Implications;
Rayleen Pirnie

August 6
Part I
Flood Insurance: Requirements and Best Practices
A Two-Part Companion Webinar Series;
David Dickinson and Jerod Moyer

August 12
A to Z of Reg E;
Andy Zavoina

August 13
Part II
Flood Insurance: Requirements and Best Practices
A Two-Part Companion Webinar Series;
David Dickinson and Jerod Moyer



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#1333736 - 01/29/10 10:47 AM Itemization of Block 1 Orig. Fees on GFE and HUD-1
raitchjay Online
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Registered: 10/15/09
Posts: 4394
Loc: OK
I am thinking maybe i have not understood this up to this point. Let's say we have in the past had an origination fee, a documentation fee, and a coupon book fee. I know those are lumped together as one fee under "origination charges" on the GFE, but i thought those were then itemized and broken out into those separate charges on the HUD-1. LaserPro even seems to be pointing you in this direction as they have the option of "include in" (for example) "line 801". Should i be telling our processors...."look, just add your origination fee, your doc fee and your coupon book fee together and enter it as one line item for both the gfe and hud"???
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Lending Compliance
#1333837 - 01/29/10 11:29 AM Re: Itemization of Block 1 Orig. Fees on GFE and HUD-1 [Re: raitchjay]
RR Joker Offline
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Registered: 11/15/02
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Loc: The Swamp
They probably built that ability in for States that require it. If your state doesn't require it, don't itemize it.
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#1333879 - 01/29/10 11:43 AM Re: Itemization of Block 1 Orig. Fees on GFE and HUD-1 [Re: RR Joker]
MarieR Offline
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Registered: 11/23/05
Posts: 568
Loc: Kentucky
I have an additional question. Since we could have the charge from an attorney for bank required doc prep we are breaking it out in the 800 series outside the column since we are not retaining the fee. I assume that if the fee is going to a third party we still need to show whom the final fee is going to, right?
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#1334046 - 01/29/10 01:16 PM Re: Itemization of Block 1 Orig. Fees on GFE and HUD-1 [Re: MarieR]
David Dickinson Offline
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Loc: Central City, NE
Nothing in Block 1, 2 or A of the GFE is itemized. They are listed in 801, 802 and 803, but never itemized. If the attorney is working for the bank, that is a Block 1/801 fee. It is not itemized.
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#1334082 - 01/29/10 01:35 PM Re: Itemization of Block 1 Orig. Fees on GFE and HUD-1 [Re: RR Joker]
Always In Training Offline
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Registered: 07/11/06
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Originally Posted By: RR joker
They probably built that ability in for States that require it. If your state doesn't require it, don't itemize it.


We use LaserPro. They built it in so that you can include in 801 for GFE purposes. They added the ability to break out these fees separately. (807-820) so that you can get your finance charges and prepaid finance charges and not finance charges right for APR calculation purposes (and HOEPA too).

(Just another software specific issue, anything put on lines after 811 aren't calculating into the totals in HUD line 1400 or the bottom A+B = Settlement Charges) You have to manually add them up and write in the true total.

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#1334089 - 01/29/10 01:37 PM Re: Itemization of Block 1 Orig. Fees on GFE and HUD-1 [Re: Always In Training]
raitchjay Online
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Loc: OK
But doesn't that mean it is going to itemize them on the HUD-1 that way too? And if so, is that a problem?
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#1334121 - 01/29/10 01:52 PM Re: Itemization of Block 1 Orig. Fees on GFE and HUD-1 [Re: David Dickinson]
MarieR Offline
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Registered: 11/23/05
Posts: 568
Loc: Kentucky
Originally Posted By: David Dickinson
Nothing in Block 1, 2 or A of the GFE is itemized. They are listed in 801, 802 and 803, but never itemized. If the attorney is working for the bank, that is a Block 1/801 fee. It is not itemized.


So HUD is ignoring the requirement to list the ultimate reciepient of the fee?
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#1334272 - 01/29/10 03:35 PM Re: Itemization of Block 1 Orig. Fees on GFE and HUD-1 [Re: MarieR]
ktac MITCH Offline
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Registered: 05/04/05
Posts: 1807
Loc: Giant side of TX
Here is the way I look at it - HUD has to make the GFE work for all 50 states.
Some states - an attny is required to prepare the docs for the bank BUT in some states there is no attny involved.
The attny requirement is a state law & just is an extra cost of business for the lender because they are in state X and not in state Y.
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#1334694 - 02/01/10 10:16 AM Re: Itemization of Block 1 Orig. Fees on GFE and HUD-1 [Re: raitchjay]
Always In Training Offline
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Registered: 07/11/06
Posts: 679
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Originally Posted By: raitchjay
But doesn't that mean it is going to itemize them on the HUD-1 that way too? And if so, is that a problem?


Again, it's a software specific answer - but Harland told me that if I have "include in 801" then it won't be itemized on the HUD-1, but will be all grouped in line 801.

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#1334851 - 02/01/10 12:15 PM Re: Itemization of Block 1 Orig. Fees on GFE and HUD-1 [Re: Always In Training]
raitchjay Online
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Registered: 10/15/09
Posts: 4394
Loc: OK
Ok....we use harland too...thanks for the input.
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#1343243 - 02/12/10 04:50 PM Re: Itemization of Block 1 Orig. Fees on GFE and HUD-1 [Re: David Dickinson]
Mrs. Rizzo Offline
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Registered: 03/07/06
Posts: 10385
Loc: Curled up by the fire...
Originally Posted By: David Dickinson
Nothing in Block 1, 2 or A of the GFE is itemized. They are listed in 801, 802 and 803, but never itemized. If the attorney is working for the bank, that is a Block 1/801 fee. It is not itemized.


David, I know this and I think the girl closing the loan knows this but the attorney is arguing saying he's going to list the fees, blah blah.
Where is this so I can fire back with a site? I can't find it!!
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#1343259 - 02/12/10 05:01 PM Re: Itemization of Block 1 Orig. Fees on GFE and HUD-1 [Re: Mrs. Rizzo]
Dan Persfull Offline
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Registered: 08/28/02
Posts: 40474
Loc: Bloomington, IN
Page 25 of the 1/28/10 FAQs

4) Q: Where should fees such as loan originator‘s Processing Fee, Underwriting Fee, and Wire Transfer Fee be disclosed on the GFE?
A: All origination charges for lenders and mortgage brokers, including fees for administrative and processing services, are included in the charge in Block 1 of the GFE, ―Our origination charge‖ and should not be itemized separately.


And from page 26:

5) Q: If a loan originator contracts loan document preparation to a third party, is this a separate charge on the GFE and the HUD-1?
A: No, loan document preparation is a processing and administrative service in the origination of a loan and is included in Block 1 of the GFE, ―Our origination charge‖ (and in Line 801 of the HUD-1), and may not be separately itemized. See 24 CFR § 3500.8(b)(1).

6) Q: Are attorney‘s fees charged to prepare loan documents for the lender considered part of the charge for origination services disclosed on Block 1 of the GFE?
A: Yes, attorney‘s fees charged to prepare loan documents for the lender are considered part of the charge for origination services disclosed on Block 1 of the GFE and should not be separately itemized.
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#1343270 - 02/12/10 05:16 PM Re: Itemization of Block 1 Orig. Fees on GFE and HUD-1 [Re: Dan Persfull]
Mrs. Rizzo Offline
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Registered: 03/07/06
Posts: 10385
Loc: Curled up by the fire...
Oh thank you, Dan!!!!!!!!!!!!!!!!!!!!!!!!!!
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