I know I've read both of these somewhere-I assume in a previous post, and I've truly searched all morning to find them again, and if this wasn't Christmas Eve, yatta, yatta, yatta . . .please help me.

Padding Costs-Can it or can't it be done under the new rules?
I understand the pricing yourself out of the market strategy, but I'm more concerned with paying off tolerances as we're already below the market in closing costs? Don't you have to retain supportive information as to where you came up with the GFE estimated costs?

Can't a reissued GFE be delivered at closing? If the customer came in for instance to pay a rate reduction fee, two days before closing, if it did not trigger a new ETIL would it be acceptable to close immediately?

Thank you all and Merry, Merry Christmas!

Ok I can't count as there are three questions up there.

And I have another-

As long as we give AfBA disclosures, can the only title insurance provider we list, be our affiliate?

Thanks again.

The GFE is supposed to be your best guess of settlement costs. I believe if you pad the fees, you are not meeting the intent of the law. I also believe examiners could cite you for not accurately providing the fees.


Absolutely. There is no waiting period between deliver of the GFE and closing.

David, I just got an email from our Regulators Regional Compliance Director; Indicating no waiting from when the applicant is 'assumed to have received' the re-disclosed GFE.
Meaning if you hand it to them you are o.k., but if you mail it you have to wait 3 Bus Days to assume they received it ????
Do you disagree with that statement from our Regulator?

He is saying the same thing. Just give it at close instead of mailing it.

I agree. Biz's question was pertaining to handing them a GFE at the closing table. There is no wait if you deliver it in person. If I mail it, I have to wait 3 days to "assume" it is received.