If a borrower pays the fees for an appraisal and credit report directly to a broker do you still include the fees in the APR when the bank discloses? Would you list them as POC and not include them in the apr?
#139943 - 12/16/0303:53 PMRe: Fees paid to a broker
Anonymous
Unregistered
In a real estate transaction those are specifically excluded by 226.4(c)(7).
In other transactions, borrower paid finance charges (if applicable) would be included in the APR no matter if they're paid POC at closing or as part of the closing transaction.
Appraisal and credit report fees are not reflected in the prepaid charges for the TIL. If paid outside of closing, they should be listed on the HUD as POC items. See TILA 226.4(c)(iii).
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#139946 - 12/16/0304:42 PMRe: Fees paid to a broker
Anonymous
Unregistered
Lets review; Borrower pays fees directly to the appraiser and to a credit agency is what the question is about. Not to the broker. The bank purchases the loan from a broker. The bank usually has to include fees charged by the broker. Still part of FC?