Thanks for your responses.
It does seem like including it in Line #1 under Origination Fee is the best option. The only amount we include there now is the amount of the Loan Fee ($150) the borrower pays to us. If we include this Lending Tree fee in Line #1, we will need to add that amount to the amount of the credit in Line #2 in order to keep the borrower from paying it. Does that make sense?
With respect to the fee we are paying to the intermediary for processing services, I believe we will include that in Block #3 (Required Services that we select)and then also add that amount into the credit amount on Line #2 so the borrower won't end up paying it.
But we won't know exactly how much we will be paying the intermediary for their processing services at the time we do the GFE. (The amount they are paid per loan depends on the volume of loans in the month--the more the loans, the lower the amount per loan.) Since we won't know the exact amount at the time we do the GFE, or possibly even when we do the HUD, should we just use the highest possible dollar amount here? Then we would use that same figure in the credit portion so the borrower isn't impacted?
RR, to answer your question,our Legal Department vetted the Lending Tree fee issue and does have some concerns under Section 8, but the decision was made to proceed anyway.