Could you please tell me where to find where HUD says the work number would go in block 3? I've been looking and I can't find it. I'd like to have it to document why we did what we did. Thanks.

small town...it was in an email response to TR...it's not written anywhere. However, it makes logical sense.

New Question - In the olden days, in those cases where we had to produce closing packages multiple times - in most cases, where the borrower would repeatedly change their minds about when they were going to close - we would charge what we called a "re-draw" fee. The idea was that the borrower would be more realistic about the closing date when there was a penalty fee invovled.

Can I consider this a changed circumstance, and if so where would I put it?

I think Truffle and I talked about this one time, so she may have a different solution. But as I see it, it would be a Block 1 fee that can't change, at least not under those circumstances. I'm not really sure how such a fee would be able to be charged.

(Repeat)
Just curious...
Is anyone NOT counting the YSP being earned on a loan for the points and fees test?
For example, if the broker chooses not to keep all of the YSP on a loan, are you still using the total amount in your calculation or only the portion the broker is retaining?

respa queen -

We haven't hit a borrower requested redraft fees yet but,imo, it would be a changed circumstance and would go in Block 2 as a cost of getting the rate. That's how we handled a borrower requested extension fee.

If someone else has a better idea, please let me know. I'm just trying never to touch Block 1.

Here is an answer I got from HUD to a question:



Has anyone ever put a POC on page 1??

If a loan is exempt from RESPA, it is optional for us to use a HUD form. If we choose to, in fact, use a HUD form for a non-RESPA loan that is closing in 2010, which HUD form do we use ... the old one or the new one?

If we have to use the new one, wouldn't that mean that we would also have to provide a GFE in order for the GFE information to be put on the new HUD form or do we simply use the new form and not fill out the GFE info.

If I attempted that, I'd use the old one.

We have some attorney's that are using the old HUD on nonRESPA covered loans.

We use the current one, and just toss page three.

Is anyone not completing box 11 (homeowners insurance) for refi's and consumer loans, just for purchases only?

Or are you always making a quote for homeowners regardless?

if the policy is due to expire within 3 months we list it....if we aren't sure, we list it....better to have it on there than not and need to add it later.

I don't see any logic in listing it if the insurance is due to expire. What if it's 4 months? Why draw the line there?

The regulation is pretty clear that you must list all settlement services. When they are paid is not a factor.

If it is a loan related POC, it should be on page 2. I would think the 200's may show, for example, taxes paid on behalf of borrower but not a loan related fee.

I agree with Sox here. We are listing them on page 2.

I agree, and he (Anthony) recanted his no POC on page two nonsense.

Right, but then I get this from HUD today:



Since when are we allowed to presume anything???

OMG! This just gets crazier and crazier. We quote a year's worth of insurance regardless of the type of loan or when it's due. Always have.

To add to this, however...do any of you see any sane reason for additionally listing it as POC on the HUD? Or a credit report, flood or anything else you didn't actually order?

Same here.

We do as well, and will continue to do so.

big arguments about it here... not sure what we will do.

Management just came to me and said we are signing an agreement with a company to assist us in doing FHA loans.
In the agreement is a statement that all loans closed will be assessed a pre-purchase, post closing review fee of $399.
This fee will be passed to the consumer.
Would I put this in as an admin fee so in block 1?
Management also wants to know if they can up the rate 1/8 and not pass this fee to the consumer and then not list anywhere? I told them no. Is that correct?

Do added p.o.c. charges constitute a change in circumstance? After providing the initial GFE, if we accept a current appraisal from our borrower that he already paid for to determine value, does this qualify as a change in circumstance? We do not require the appraisal, but the borrower has provided it to help prove his property value. There is no increase in charges, so do we need to re-disclose? (Our appraisal dept. reviews the appraisal.)

"if we accept a current appraisal from our borrower that he already paid for to determine value"


That might not be the best of examples, as the appraisal rules would not allow you do that.