Can someone translate the point and fee calculation for me on an elementary level, PLEASE! I am so confused on what to count and what to exclude.

Anyone have this figured out in a simple form yet? Especially for a small creditor?

I broke it down based on our limited fee setup. I hope it's right! Problem with a simple form is - noone is truly created equally.

Ours would be:

Loan fee
In-house appraisal fee
VSI
Any referral fee paid to an employee (if we had that plan)

^^ I think you can take out the referral fee if it is being paid to an LO employee.

ii) All compensation paid directly or indirectly by a consumer or creditor to a loan originator, as defined in § 1026.36(a)(1), that can be attributed to that transaction at the time the interest rate is set unless: .................



(C) That compensation is paid by a creditor to a loan originator that is an employee of the creditor





ETA:

We are using:
Origination
Processing
Broker
Life of Loan Flood
In-house Appraisal

I'm missing flood for some reason!

I didn't finish up there...I think it does apply to a non LO employee, like a teller...I better brush back up on that now that time is near!

Please tell me what you consider a "processing fee" is that what you charge at your bank to process the loan or is that your attorney doc prep or title co doc prep fees?

Also what about these 2nd appraisals if deemed necessary? As long as we're paying a 3rd party and we're not taking any compensation then we're ok to exclude?

Internal processing fee that the bank keeps.

I do not believe the second appraisal would be counted.

ok thanks and thanks!

Why are you including Life of Loan Fee? Is that not excludable as a bona fide third-party charge?

^^^ I believe you are correct. I had left that on my calculator from the previous rule.

For clarification, with regards to the points and fees test only, this fee would not be included, but for purposes of the APR calc and Reg Z, you would include as a PFC. Is that correct?