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#2024320 - 07/01/15 02:13 PM "Flat closing cost bundle"?
Compli(cated) Offline
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Joined: Mar 2011
Posts: 185
Wisconsin
One of my favorite types of questions came from the mortgage department this morning:

They heard on some webinar an attorney say that there is nothing in the reg that would prohibit us from charging a flat closing cost fee bundle. They would like to disclose it as one item under the Services You Cannot Shop For.

I am seeing plenty in the reg that specifically requires itemization, but just wanted to check if there is something else that I am missing?
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TRID - TILA/RESPA Integrated Disclosures Rule
#2024464 - 07/01/15 05:32 PM Re: "Flat closing cost bundle"? Compli(cated)
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 80,325
Galveston, TX
So, if it is a service they can shop for - which vendors in your area offer a single charge no matter what is required??
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#2024544 - 07/01/15 07:41 PM Re: "Flat closing cost bundle"? Compli(cated)
Compli(cated) Offline
100 Club
Joined: Mar 2011
Posts: 185
Wisconsin
Apparently now we itemize the costs under the services you cannot shop for anyway and just eat the the difference if there is any in the end. Everyone gets the same prices quoted that add up to the advertised closing costs.
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Opinions are my own.
"I was gratified to be able to answer promptly. I said I don't know." - Mark Twain

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#2024605 - 07/01/15 09:22 PM Re: "Flat closing cost bundle"? Compli(cated)
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 80,325
Galveston, TX
just eat the the difference if there is any in the end.

By eat the difference, I hope you mean that you provide an appropriate cure. You can't not disclose the actual costs.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2024826 - 07/02/15 07:17 PM Re: "Flat closing cost bundle"? Compli(cated)
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,862
Cape Cod
There's nothing in the regulation allowing you NOT to itemize the actual charges on the CloD. And that will cause all sorts of problems for you in calculating the cure, since you will have charges for which you provided no estimated amount.

Just don't go there!
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John S. Burnett
BankersOnline.com
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