We were told early on by our local title company that the $3.00 Illinois Agent Registration Fee had to be listed separately on GFE & HUD. Does anyone one know how this should be listed? We keep having trouble getting the Hud to balance at loan closing because of this, we are always $3.00 off when doing purchases.

Wherever you're putting this on the GFE has a corresponding place to put it on the HUD so I'm not unerstanding why you're not balancing.

What is this fee for, to whom is it paid and by whom?
Fees that are common and customary as paid by the seller do not have to go on the GFE. State Law can also come into play as it does here in WI with transfer tax.

Lastly, a local title company would not be my choice for authoratative answers on RESPA.

We use Line 1110 for borrower & Line 1109 for the seller. 1109 is coded to go to GFE Block 5 and 1110 is coded to go to GFE Block 4.

We have no idea what this fee is for but it is paid to the title company and paid by both parties. We were told it had to be listed separately by a lawyer's office that does title work for us sometimes, they had gone to a class before the Reg. changes had come into effect. At HUD time, the borrowers fee carries over but the sellers fee does not and I am always off $3.00.

So these are add-ons to the cost of title insurance. I guess I don't understand why both Block 4 and Block 5 don't then include the $3 as part of the fee and be carried over in their entirety onto the HUD on 1103 and 1104 respectively.

I suggest you take this question to the IL forum and see what responses you get there.

btw, we do loans in IL and I've not seen this fee broken out on any of our loans.

Thanks for trying to help. I will post this in the IL forum.

Got confirmation from my Illinois source. This fee should not be seperated out from the cost of lenders and/or owners policy. Just show it as part of Block 4/5 and carry it over to 1103/1104.

I suggest you go back to the title company and ask them for a sitation from the Reg or an email from HUD, something that explains why they think it should be seperate. Remember, come examination time, your bank is responsible for proper placement of fees on the GFE and HUD. The title company has no skin in the game, as it were. Nor does the attorney.

That's interesting. It's always separate on the HUD's Ive seen (for the REO property that I sell).

I'm not sure if it's placed on the GFE, as we don't lend on most of our REO's.

On the HUD it's on line 1204 (listed as "DFI Policy Fee")

DFI? Is that the same as Illinois Agent Registration Fee? (I'm not in IL, obviously.)

IN has a TIFF fee that is charged by the state and collected by the title agents for each title policy sold. It funds some sort of state coffer. It has to be paid even if we do the closing.

Under state law this fee has to be itemized on the HUD. It's shown outside the column in the 1100 series but is included in the 1101 total. It's included in the Block 4 total on the GFE.

Is this a similar IL fee? If so check IL law as to whether it has to be itemized on the HUD.

That's the ONLY Illinois $3 fee I know of. I talked to my title guy and he said they remit $3 to state of Illinois for each deal at the end of every year.

He also said that all the lenders he know put this in the 1200's. (Obviously, citing the title guy is not compliance so much as being lazy and showing deference.)

Where ours is related to title insurance it sounds like this fee is some sort of state tax since it's being disclosed on Line 1204. If it is a state tax then it should be disclosed in Block 8 on the GFE and Line 1204 or 1205 on the HUD.

Sounds similar.
Our's goes on the GFE in block 4 and then on the HUD in the 1100 series (1109-1111) it states "Illinois State Policy Fee to (Title Company's Name)"

QCL – MamaBEAR:

(1) do you treat this as APR sensitive?

(2) does this fees place on the HUD vary depending on whether it is a refinance or purchase?

QCL, must this fee be broken out according to state law?
Does it then get included in the 1101 line or go out in the column?

Thank you for chiming in on this, Roomie.

1.Don't recall about the APR.
2. Shows on both refi and purchase.

3. It is included in the 1101 total and then shown broken out somewhere in lines 1109-1111. (I am doing this from memory - if you need something more exact I can pull a HUD). You'll find a way to repay me in a few minutes check your email

Thanks for all the responses!

MamaBear, question for ya, seems like you are doing it the way we do but I am always off on purchases. I put the $3.00 on both sides using 1109 & 1110. Borrowers cost pulls up to line 1101 just like you said but the sellers never pulls up to line 1103. How do I get it to add to that? Or should I be putting it some place else?