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#1351994 - 03/03/10 11:17 PM Itemized Fee Worksheet
Brandy Friesen, CRCM Offline
100 Club
Joined: Aug 2006
Posts: 136
Colorado
Our mortgage department uses Encompass to create their early disclosures. It was just brought to our attention that there is a worksheet that is available to accompany the GFE.

Is anyone else using this type of worksheet to show a better estimation and itemization of the fee's being charged in connection with the loan?

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Lending Compliance
#1352120 - 03/04/10 02:23 PM Re: Itemized Fee Worksheet Brandy Friesen, CRCM
Mrs. Rizzo Offline
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Mrs. Rizzo
Joined: Mar 2006
Posts: 10,392
Curled up by the fire...
We require a "Initial Fee Worksheet" to accompany each GFE. If there is a changed circumstance, that form must show each fee being changed as it relates to the changed circumstance.
We do this mostly because it is a requirement of our investors and...it's nice to make sure the brokers are still trying to screw over borrowers smirk
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#1352297 - 03/04/10 04:35 PM Re: Itemized Fee Worksheet Mrs. Rizzo
Brandy Friesen, CRCM Offline
100 Club
Joined: Aug 2006
Posts: 136
Colorado
I can understand the investor wanting a copy of this form. However, we are questioning if it is appropriate to give to the customer. We are considering the risk that the additional disclosure may be confusing to the customer and that the GFE would become less of a priority in the eyes of the lender in explaining fees to customer.

The GFE is already confusing, but if we provide this to the applicant, would we be perceived as trying to circumvent the RESPA requirements in the eyes of the examiners?

I am not finding anything in the reg or FAQ that says we can or cannot have this separate itemization. Any input?

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#1352375 - 03/04/10 05:33 PM Re: Itemized Fee Worksheet Brandy Friesen, CRCM
Brandy Friesen, CRCM Offline
100 Club
Joined: Aug 2006
Posts: 136
Colorado
I just found on page 9 queston #27 in the RESPA FAQ states...
Q: May additional pages be added to the GFE to allow for all charges to be shown? If so is it an addendum or an extension of page 2?
A: No. Additional pages or addendums may not be added to the GFE.

Just thought I would share this for those of you are reading this thread.

We are thinking that a separate itemization would be considered an addition or addendum by our examiners and could put us in violation of RESPA.
Last edited by Brandy F; 03/04/10 05:34 PM.
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#1352395 - 03/04/10 05:45 PM Re: Itemized Fee Worksheet Brandy Friesen, CRCM
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
I don't think the itemization is an addition page unless it it referenced as such. IOW, you can anything you want in the loan file (the itemization). If the GFE references it or states "page 1 of 4), then this would not be allowed (the GFE is only 3 pages long).
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#1352658 - 03/04/10 09:03 PM Re: Itemized Fee Worksheet David Dickinson
Mrs. Rizzo Offline
10K Club
Mrs. Rizzo
Joined: Mar 2006
Posts: 10,392
Curled up by the fire...
Sorry, I misunderstood your question.
We absolutely do not give the fee sheet to the borrower. They don't even see that document. That is for internal use only.
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