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#2020128 - 06/12/15 04:14 PM DOC PREP FEE/
newyork Offline
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Currently we choose the attorney to prepare the bank documents and include that fee under our origination charges under the current RESPA. For the new disclosures, we are still going to choose the attorney to prepare the bank docs, does the doc prep fee still continue to go under origination? or section b services you cannot shop for under the LE?

and for the CD, where will that doc prep fee go?

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TRID - TILA/RESPA Integrated Disclosures Rule
#2020146 - 06/12/15 05:01 PM Re: DOC PREP FEE/ newyork
RR Joker Offline
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This is just a 'for curiosity's sake' question...but what bank documents do you have an attorney prepare for you?
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#2020161 - 06/12/15 05:29 PM Re: DOC PREP FEE/ newyork
newyork Offline
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Legal docs only. Note, security agreement.

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#2020165 - 06/12/15 05:43 PM Re: DOC PREP FEE/ newyork
RR Joker Offline
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RR Joker
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IT would seem to me that any [fee for] docs relating to perfecting the title would go under "you can't shop" and any bank specific (ie, note) would go under origination.

Others please pipe in!
Last edited by RR Joker; 06/12/15 05:44 PM.
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#2020171 - 06/12/15 05:56 PM Re: DOC PREP FEE/ newyork
newyork Offline
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I agree it would be under "you can't shop", what I am not certain is if we include it under Loan Costs, Section A, Origination Charges?

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#2020179 - 06/12/15 06:09 PM Re: DOC PREP FEE/ newyork
Dan Persfull Offline
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Dan Persfull
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Bloomington, IN
Review the Commentary to .37(f)(1). Origination charges are charges "paid to" the loan originator(s). Fees paid to a a 3rd party are not paid to the loan originator, they are pass through costs. The .37(f)(1) Commentary also refers you to the Commentary for .19(e)(3)(i) where it is discussed when a fee is considered "paid to" a person.
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#2020184 - 06/12/15 06:24 PM Re: DOC PREP FEE/ newyork
RR Joker Offline
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RR Joker
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The Swamp
True...and I just read that again like yesterday. crazy
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Say you'll haunt me - Stone Sour

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#2020185 - 06/12/15 06:28 PM Re: DOC PREP FEE/ newyork
John Burnett Offline
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John Burnett
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Cape Cod
Based on discussions in another thread, I'll add here that this Document preparation service can be listed in Section B (Services You Cannot Shop For) or Section C (Services You Can Shop For), depending upon the obvious: whether you will or will not allow the consumer to identify and use his own provider for this service. I admit to not understanding the logic behind allowing a consumer to select an attorney who will do the lender's security instrument and note, but apparently there are those lenders who permit it (or are required to permit it).

On the CloD, it will appear in Section B if it was in Section B on the LE. If it was in Section C on the LE, it will go in Section B if the consumer picked someone from the providers list, or failed to select someone. It will go in Section C if the consumer selected someone other than the provider(s)+ on the providers list.
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