Third Party Service Provider for Flood Determinations was changed, but no communicated to staff. The fee went down $1.00. I've asked that they review any other fees they're charging before we start a goback project.

What exactly should be done in this situation? Determine when the provider and fee changed and go back to all those loans and see if the TIL is affected and the HUD tolerances? Then reimburse APR errors and cure any tolerances?

I have never been involved in anything like this before and I'm wondering what exactly needs to be done to cover all bases.

One of the findings in the exam report that resulted in me getting hired here 10 years ago was a charge exactly $1 more than the actual FZD charge, not because of a vendor change but because of a price change that no one paid attention to. We had to go back to the date of the price change and refund the $1 for every one charged the fee from that date forward.

The manager says that the borrower is not charged for the inital fee of $9 we have been disclosing because its in a lump sum charge and only the $6 life of loan is disclosed. Because they generally (not always)are given a credit for the lump sum origination charge, they aren't charged. I say they are. It is a fee associated with making the loan charged to the borrower and then we give them a credit. It just isn't paid by the borrower.

I'm starting to talk in circles and we have tabled this for today. Am I looking at this wrong?

You will have to review each file to determine the ones given a credit and those that were not. The ones that were charged the extra $1 will require a refund.