Splitting has been addressed with this post. Many would rather slug through this one thread knowing the answers are here somewhere rather than try to keep up with numerous offshoot threads.

yes, use the payment amount you listed in Blk 4 and check no.

The HUD "Plain English" description of how to handle YSP seems to contradicts HUD's own instructions in Appendix C. It also definitely contradicts Compliance Coach's Guide to getting it right as well as Ivy Jackson's RESPA Lawyer's blog that is a very clear example that the YSP is included in Box 1 and credited back in box 2. I've contacted our resource for clarification. Has anyone else in the wholesale business noticed this?

If you plan on keeping any of the YSP, you will have to disclose THAT amount in block 1. Any piece of any credit back to the borrower will go in 2.

That's not how it's portrayed in The "Plain English" pricing examples, there is no YSP in box 1 (orignation charges), just a credit in box 2.

That was my point in another thread on this same topic. It's natural HUD wouldn't show it in the origination fee as their original intent/acceptance of a YSP is for it to go to the borrower as a credit to offset costs.

Rate buydown = paying more
Rate buyup = paying less

It was never really intended for the broker/lender to profit.

This morning I tried calling HUD to find out what the heck is going on. I got passed around a lot, and nobody knew what I was talking about. I finally learned their formula for e-mail addresses, and proceeded to express my frustration in an e-mail to Brian Sullivan (the PR contact on the press release), Vicki Bott (the speaker), and just for giggles, Secretary Shaun Donovan. I actually got a reply back from Brian Sullivan, which said:

"There is limited capacity for each of our presentations requiring us to do invitations via RSVP. The Mortgage Bankers Association is assisting in getting the word out but perhaps you didn’t get word through your trade association. Having said that, the session for December 16th looks pretty good. If you’re interested, we can give you specific instructions as to how to access that presentation. Otherwise, we do intend to post one of our presentations online shortly."

So, it sounds like the mulitple presentations are just repeats of the same thing. I also received a telephone call back from a staffer in the Public Affairs office, offering to take my e-mail address and e-mail me an invite. Call the number on the press release 202-708-0685 if you'd like to try the same thing.

Man, what a pain!!

I feel like a dumas... have my timezones mixed up today, and logged in promptly at noon, as it was concluding after adding an hour to the start time vs. backing up an hour.

<--- idiot

1.Am I correct in stating that Block 1 (our origination charge) is considered an interest rate dependent charge?
2.If we disclose $1000 but it changes to $1500 within the 10-day window do we have to re-disclose on a new GFE assuming it is considered an interest rate dependent charge?
I'm reviewing 3500.7(c).

The only way you might be able to do that is at rate lock. See page 1 of your GFE important dates. It states that some origination charges, etc may change until you lock your rate.

if the customer purchases a rate lock at some point after you provide the GFE - is it mandatory to send out a revised GFE showing the locked interest rate? The BOL Q and A #28 makes it sounds like redisclose is only optional.

If it causes a change in fees and P&I, I definitely would.

Sage, they addressed this specifically in the HUD webcast today.

Quote:

At lock, an updated GFE must be issued with "Important Dates" sections updated. Line 4 may contain "N/A" at this point.

As a follow up to Jokers reply, I thought it was required due to confirming the appropriate dates in the "Important Dates" section. I seem to recall reading in on of the many FAQ's or power points that it was redisclose was required at lock.


edited to add: Truff beat me to it!

I think all five of these sessions are basically the same. There were only around 300 takers on today. (They show a count of who's listening.) I had the hard copy of 12/3 and there were only a couple additions for today's webcast based on 'industry input'. I think I'll be ok skipping the others as long as I print out the powerpoint and compare them.

It makes sense since the date info will definitely change.

Do i have this right: Block 1 of the GFE would include both our origination charge and a doc fee (if the fee is being paid to us)? Basically, the way i understand this is...if the fee is being paid to the loan originator (us), it has to go in block 1. Please correct me if i'm wrong.

To get an invite I have to call the number posted above?

No, block 1 is not interest rate dependant and cannot change at the point of the rate lock.

We use a contract processor and she is paid through escrow directly. Can we put her fee in the Block 3?

Try the email address I posted. The fourth time I called they gave me the email address and within minutes I had the invite in my email.

Block one could change at rate lock if the borrower chooses to pay point(s) that was not previously discclosed, or if they lock at a no point rate that was previously disclosed with points.

Not necessarily. If your settlement agent is charging a fee to prepare documents for you, then that would go in there as well.

It's going to be interesting to see how, at rate lock, if locked at an above par rate in which a lender/broker intends to keep a portion or all of the YSP, how THAT's gonna look! But, to me Sox...the above you have mentioned should really just affect box 2, unless you intend to check box 1 of Block 2, And that can only be done if you fund the loan, so a broker or non-funding FI can't do that.

We don't have broker deals (Thankfully). I am planning to include points, if any, in box 1.