In a recent QandA section of New HUD 1 info it states you must list fees for previously used appraisal and flood det on a refinanced loan for GFE and then list as POC on HUD if not getting updated appraisal and flood det. Is this correct?

yes, anything you require, but use an older version of should be on there. Same as hazard insurance even it a policy is currently in force.

Is this in writing somewhere?

Staff here asked an interesting question, too - if they got the survey a long time ago, how do we know what they paid for it? I've told them all we can do is list what the current going rate is on those if we don't know what they/we paid originally. Flood determination and appraisal you won't probably have this come up much, but for survey, you probably will.

Can someone please include a specific reference to the FAQ as I cannot locate this info.

Thanks

I've been looking for this too and haven't been able to find it, any help would be appreciated. Thanks.

You won't find a FAQ. Appendix C states to include all settlement fees. It also tells us not to identify anything as POC. So when it is paid for or by whom is not a factor.

When you put all of that together, the logic tells us to list everything - even if it's already paid for.

Would this work the same when we're doing a simultaneous second lien (piggyback) for a purchase? For example, we list the fee for the appraisal on the GFE for the first lien. Would we also list that same fee on the GFE for the second lien and then show it as POC on the HUD-1?

bump

Deena, to me it would depend on whether you require it. Chances are you really won't be requiring it because you have it.

Now, look at it this way. John Doe lender makes the first and you are making a second. You will require an appraisal. If you accept an assignment of the appraisal done for the first, you will show the cost (these are what I call "ghost" costs).

I don't require every single little thing to necessarily be shown...but if it's required, then we expect it to be shown...ghost, real, or anything in between!

Thanks very much for your response. That makes sense. I think we get so caught up in trying to figure out HOW to complete the forms that we forget to consider whether we even NEED to complete the forms - at least that's the case for me. I appreciate your help.

But do you offset the fee that has been previously as a credit in block 2 or do you leave block 2 blank and put the charge in as POC on the Hud

I'm having a hard time understanding this. Appendix C states that we must list required settlement services and an estimated price to be paid to the provider of each service.

If a new appraisal and/or flood determination isn't required on a refinance, then we have no one to pay.

The thought is: would you make this loan without an appraised value or without knowing if the property is in a flood zone? If the answer is "no", then it is a required service and while not ordering a new one for this loan, you are still "requiring" it and the customer (or someone) paid for it previously, therefore, you list it. Not saying how wonderful or intelligent that is, but that's the thought.

I totally get where we have to list previously paid fees (like appraisal, flood determ, et.) if required on a subsequent loan; however, do we have to list previously paid fees such as origination fees and recording fees? My scenario involves an increase to a covered construction loan where we are charging 1% origination fee on the new money. We had charged a 1% origination fee on the original construction loan. My thought is that I'd have to show the total origination fee (old fee and new fee) on the GFE and then on the HUD show a credit in the 204-209 series for the old fee previously paid. Same thing for the fees previously paid for the deed of trust?

Is this over-kill or over-thinking this? Thoughts anyone?

I think that is overkill. An origination fee is different than an appraisal fee or flood fee, to me, because a bank does not "require" an origination fee to close a loan. I mean...it's a fee that a bank charges to make money on the loan. I do not think it would be correct to combine all origination fees from previous loans and show it on the GFE. Show the origination fee associated with this loan only.

I like your answer Raitchjay...Thanks!