I would guess that until a customer chooses a provider, you can't complete the GFE. When they make their decisions as to which providers to use, you can complete the GFE accordingly. JMHO

Really! That would solve some problems about estimation- but that answer is too easy and doesn't fit this Reg. Thanks!

I am filling out a training HUD statement, if a client pays for the appraisal POC--how is that disclosed on the HUD?

Correct - you cannot reissue a new GFE with the higher fee. The HUD-1/1A will list the higher fee in the HUD column of the tolerance table. IF the total of this column is >110% of the GFE column total, you'll have to cure (eat) the difference.

List on line 804: "appraisal fee to [name of company] $xxx (POC - Borrower)". No dollar amount will go in the borrower's column. Then you list the fee in the tolerance table. POC doesn't matter for the GFE or tolerance tables.

How do we dislcose credit life premiums on the HUD if all of the premiums are financed? I am being told to put them in the 900 series.

Whether fees are financed, doesn't matter for the Settlement Statement. You are correct, these go in the 900's.

Where did you show credit life on the GFE?

Not shown because it is not required. It's optional to the borrower.

DU and LP underwriting charges. Do they belong in block 1 as part of the origination charge or in block 3 as a required service?

I've read up on the earlier discussions on taxes, but am not sure that this scenario has been addressed: if a first loan payment will fall after a tax payment is due, and we plan to collect the tax payment at closing, should the tax payment be disclosed on the GFE? If so, in what section?

Ditto the DU/LP charge question...

David answered the LP or DU fees in the Q&A of his webinar.
Underwriting fees (LP or DU) should be disclosed in Block 1 of the GFE. A credit should be listed in Block 2 if the lender knows prior to issuance of the GFE that it will absorb the fee.

pjs-I don't know how a GFE can be issued if they haven't chosen a provider.

Why not? I thought that was the entire basis behind using the highest bid on the list if you don't know who it will be yet.

So go with a high quote as a CYA, then they let you know who to use?

You must issue a GFE BEFORE they pick a provider. The borrower doesn't know WHAT you require or WHERE to get the services from. That's what the GFE tells them.

If you want, you can choose all providers. Then you'll know the fees. If you allow them to shop, you can still provide the estimated cost of your recommended providers. IF they choose one of those, you get a 10% tolerance. If they don't choose one of your recommended providers, it's an unlimited tolerance. I guess I don't see the problem with not knowing the provider and issuing a GFE.

LOL, I do that Sesame Street thing all the time with my kids. They look at me like...well, that's another story.

MORVision. And I don't agree that they can add the Signature line tot he GFE, sorry if I gave that impression. I also don't believe it is correct to make it 8.5 x 14. That is not what size the model is.

Far as the Signature Page for teh HUD, that is permissible, especially the way they do it. IT is a seperate page that just shows they reviewed the HUD and that it is accurate to the best of their knowledge.

Read Daves response to the same questions I asked

#1260651 - 10/02/09 09:41 AM Re: RESPA changes 1-1-10 [Re: jlroberts]

He says: You won't know who they are using until AFTER the GFE is issued. You must make your best guess of the fee BEFORE they choose a company and list that fee on the GFE.

OOPs. I started this reply when I came to work this am and just got back to it. I didn't see that Dave already responded.

Thanks all for the provider list answers.

I'm so glad THAT got cleared back up...I thought I had missed something somewhere along the way...good GOLLY miss MOLLY!

I love RESPA, I love RESPA, I love RESPA....really, I do.(not)

Fair enough. I guess I need to clear out the cobwebs.

My problem I can read it and understand it and get it in my head then something else comes along to question my thought process and then I get confused.

Here's my thinking on it and I ran this by HUD (the previously mentioned Cheryl) who said it would work (of course anything they tell you is unofficial). Credit life is part of the balance of the loan which shows up on the GFE under "Your initial loan amount is ". Like you say, there's no explicit disclosure of it on the GFE. The instructions for the HUD-1 and the recently updated FAQ state that Lines 104 and 105 are for additional amounts owed by the borrower, such as charges that were not listed on the GFE. This seems to fit credit life perfectly. In addition if you list it here instead of the 900 series, it won't show up on the comparison chart on the HUD-1, thus looking strange with a charge in the HUD-1 column for credit life and a blank for the GFE column. Like I said, that's the unofficial take on the issue.