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#107131 - 08/15/03 09:56 PM Reg Z - Itemization exempt
tuma Offline
Gold Star
Joined: Feb 2003
Posts: 368
Here & There
We are receiving some audit exceptions for incomplete Reg Z Itemizations on Res Mtg Loans we have originated and sold. My understanding has always been if the loan is subject to RESPA, and RESPA disclosures given, that the itemization is not required. In our TIL we give at closing we state "Per HUD-1 Settlement Stmt" or something similar in the Itemization area. My reading of Supplement I, Paragraph 18(c)4 confirms this to me. Does anyone else have a different understanding of this?

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Lending Compliance
#107132 - 08/15/03 10:26 PM Re: Reg Z - Itemization exempt
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
You're correct. You DO NOT have to itemize the amount financed if you give a GFE and HUD-1/1A. See footnote #40 [226.18(c)(1)] and the commentary to 226.19(a)(1)#5.
_________________________
David Dickinson
http://www.bankerscompliance.com

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#107133 - 08/16/03 12:31 PM Re: Reg Z - Itemization exempt
tuma Offline
Gold Star
Joined: Feb 2003
Posts: 368
Here & There
Thanks.

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#107134 - 08/16/03 03:09 PM Re: Reg Z - Itemization exempt
Richard Insley Offline
10K Club
Richard Insley
Joined: Oct 2000
Posts: 10,049
Toano, VA
Schedule your auditors for remedial Reg. Z training. If they're "catching" things like this, what are they missing?
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...gone fishing.

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