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#1740860 - 09/14/12 01:15 PM Dual Compensation?
WHEDA Offline
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WHEDA
Joined: Apr 2009
Posts: 189
Wisconsin
In a table funded transaction, if an investor pays an origination fee to the originating lending institution as part of the funds transferred to facilitate the closing, can the originating lending institution charge the borrower an "appraisal ordering fee" (administrative fee for ordering an appraisal)?

Same scenario, can the originating lending institution charge the borrower a closing/settlement fee if they close the loan in-house vs. using a title company?

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RESPA
#1741043 - 09/14/12 05:36 PM Re: Dual Compensation? WHEDA
WHEDA Offline
100 Club
WHEDA
Joined: Apr 2009
Posts: 189
Wisconsin
Bump

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#1741060 - 09/14/12 05:50 PM Re: Dual Compensation? WHEDA
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,388
Galveston, TX
I would say not. As a broker, you can only receive compensation from one or the other and not both.
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#1741215 - 09/14/12 08:51 PM Re: Dual Compensation? WHEDA
WHEDA Offline
100 Club
WHEDA
Joined: Apr 2009
Posts: 189
Wisconsin
Randy, are you saying no to both scenarios; the appraisal ordering fee and the closing/settlement fee?

The reason I am asking for clarification is I seem to recall reading somewhere that if a loan originator, in their normal course of loan origination, closes loans in-house they can receive their standard fee for that service from the borrower even though they are receiving YSP or some other fee simultaneously from a wholesale lender and it would not be considered dual comp.

My memory sucks!

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