Fees For In-House Flood Determination - Mary Beth Guard

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Fees For In-House Flood Determination
by Mary Beth Guard, BOL Guru

Question: Are you allowed to charge a fee, for instance $15.00, for an in-house flood determination that would be done by a loan officer? Are there any banks doing this?

Answer: It is permissible to charge a fee for an in-house flood determination and some financial institutions are doing so. Keep in mind that on closed end dwelling-secured loans, in determining whether your total fees trigger coverage under HOEPA, you would have to include the amount you charged for a flood determination, since that fee would be going directly to your institution.

The original version appeared in the March 2003 edition of the Oklahoma Bankers Association Compliance Informer.

First published on BankersOnline.com 8/11/03

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