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#1856519 - 09/27/13 05:25 PM Discontinuing Average Fee Method - RESPA
RGS Offline
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RGS
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Home of the 8 time NCAA Champ ...
We are considering making a recommendation to management that we stop using the "average" method of credit report fee calculation.
If we decide to do this - is it as simple as getting the powers that be to sign off, changing our procedures, and doing it?

OR - do we have to do something to validate the average fee that we've used over the most recent term - and if that validation showed that our average fee was too high, would we have to go with an average again for the next 6 months at a reduce rate to make up for it as per the regs before we could abandon the averaging method entirely?
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#1856546 - 09/27/13 05:54 PM Re: Discontinuing Average Fee Method - RESPA RGS
RR Joker Offline
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The Swamp
Did something change that now allows you to know up front what the actual charge will be?
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#1856673 - 09/27/13 07:36 PM Re: Discontinuing Average Fee Method - RESPA RGS
RGS Offline
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RGS
Joined: Jul 2002
Posts: 689
Home of the 8 time NCAA Champ ...
Yes.
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Kentucky basketball isn't a matter of life and death, it's much more important than that.

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#1856706 - 09/27/13 07:57 PM Re: Discontinuing Average Fee Method - RESPA RGS
RR Joker Offline
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RR Joker
Joined: Nov 2002
Posts: 20,654
The Swamp
I think that if that's the case, I would document the reasons, stop calculating the 6-mos average, and begin charging the actual charge.

Whether you do that now, or at the beginning of your new 6-mos period probably doesn't matter too much.
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

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