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#2019934 - 06/11/15 06:31 PM LE or CloD Delivery / Courier Fee
travelgirl Offline
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Joined: Mar 2004
Posts: 223
Our implementation team has been discussing ways to "prove" delivery of the LE and CloD in order to speed up the "3/6" day time frame.

One option is to overnight the disclosures via Fed Ex, UPS, etc. If we choose to overnight or courier the disclosures and obtain a confirmation of delivery (i.e. delivered on 6/10/15 and signed for by applicant John Doe), can the bank pass the delivery / courier fee on to the consumer? And if so, which box / section would the fee be listed on the LE and CloD?

In the old days we couldn't charge a fee to prepare the GFE, but not sure about this sort of fee.

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TRID - TILA/RESPA Integrated Disclosures Rule
#2020033 - 06/12/15 12:45 PM Re: LE or CloD Delivery / Courier Fee travelgirl
Carolina Blue Offline
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Carolina Blue
Joined: Jul 2005
Posts: 954
Lost in a regulatory fog
You can certainly charge the fee. I think you have the option to itemize it or not. Either bump up your origination fee and "eat" the delivery fee so it's not listed on the LE or charge it separately and list it in Section B. Services You Cannot Shop For.

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#2020243 - 06/12/15 09:15 PM Re: LE or CloD Delivery / Courier Fee travelgirl
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
In the old days I worked at banks that treated this as overhead, considering it as postage and did not disclose the fee. This was about the only third party fee we treated as overhead, because we did not itemize for stamps no matter how many were used.
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy

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#2021355 - 06/18/15 08:28 PM Re: LE or CloD Delivery / Courier Fee Kathleen O. Blanchard
travelgirl Offline
100 Club
Joined: Mar 2004
Posts: 223
Thanks for the responses. I also dug a little further and found the following in 1026.19. I may be interpreting it wrong but it seems to prohibit charging for the preparation and/or delivery of the CloD. Thoughts?

1026.19(f)(5) states this:

5) No fee. No fee may be imposed on any person, as a part of settlement costs or otherwise, by a creditor or by a servicer (as that term is defined under 12 U.S.C. 2605(i)(2)) for the preparation or delivery of the disclosures required under paragraph (f)(1)(i) of this section.

(f) Mortgage loans secured by real property—final disclosures.
(1) Provision of disclosures.
(i) Scope. In a closed-end consumer credit transaction secured by real property, other than a reverse mortgage subject to § 1026.33, the creditor shall provide the consumer with the disclosures in § 1026.38 reflecting the actual terms of the transaction.

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