Hi! I attended a lending update class in April in San Antonio and the 3% fee cap was addressed. Of course you are not required to make loans at a loss. The 3% rate cap is justifiable to raise the loan amount threshold and should be documented IN YOUR POLICY because it could be a fair lending issue (disparate impact). That's why it's recommended to document the heck out of it and counter with it being a "business necessity". Also, in your policy, include a dollar limit amount of what the minimum amount of your home equity can be because of the costs. Keep documentation for proof.
FYI: FEE Limit includes all fees to originate, evaluate, maintain, record, insure, or service the loan.
DOES NOT INCLUDE:TITLE POLICY, PROPERTY INSURANCE, VOLUNTARY CREDIT INSURANCE, OR TAXES
Last edited by Lil'Belle; 10/02/14 04:38 PM.
_________________________
Chiquita pero picosa.