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#2012396 - 05/06/15 03:42 PM Application fee
sunnyflowers Offline
100 Club
Joined: Feb 2009
Posts: 150
North Carolina
If credit report fee and flood fee are included in application fee....does new TRID requirements require these broken down and listed separately on the LE/CD or can they remain disclosed as application fee? Thanks!

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TRID - TILA/RESPA Integrated Disclosures Rule
#2012409 - 05/06/15 04:05 PM Re: Application fee sunnyflowers
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
The credit report and flood fees are for services the consumer cannot shop for. They are to be disclosed in section B on page 2 of the LE.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#2012419 - 05/06/15 04:22 PM Re: Application fee sunnyflowers
sunnyflowers Offline
100 Club
Joined: Feb 2009
Posts: 150
North Carolina
ok...so for example, application fee is $50.00 (and credit report fee and flood fee are included and paid from that amount)
and application fee is listed in section A on page 2, then you would also list these fees separately in Section B on page 2? Looks like that would make the total to include the fees twice? Straighten me out Dan! My Monday must be carrying over to Tuesday. I am sure I am making this more complicated than it really is! Thanks!

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#2012441 - 05/06/15 05:08 PM Re: Application fee sunnyflowers
sunnyflowers Offline
100 Club
Joined: Feb 2009
Posts: 150
North Carolina
Never mind....light bulb just came on! New TRID requires individual listing of charges. So items have to also be listed as you said in your answer. Thanks!

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#2012495 - 05/06/15 06:27 PM Re: Application fee sunnyflowers
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Your Monday really lasted a long time, since it's actually Wednesday. wink But the dawn arrived, and you have the answer you needed (and Tuesday was probably a good day to have skipped).
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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#2012500 - 05/06/15 06:32 PM Re: Application fee sunnyflowers
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
I hate to rain on what was starting to be a nice day, sunnyflowers, but collecting that fee in a lump at the time of application could be a problem. Under 1026.19(e)(2)(i), the only fee you can collect before you issue a loan estimate and the applicant has indicated an intent to proceed is a "bona fide and reasonable fee for obtaining the consumer's credit report." You'll have to collect the flood zone determination fee separately.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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#2012518 - 05/06/15 06:51 PM Re: Application fee sunnyflowers
sunnyflowers Offline
100 Club
Joined: Feb 2009
Posts: 150
North Carolina
Okay...got my umbrella up! Thank you so much for your help on this! (And even on figuring what day it is! Lol). You have certainly cleared all this up for me! Think I might can put the umbrella down now.

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