Skip to content
BOL Conferences
Thread Options
#2038573 - 09/15/15 05:33 PM Need other banks' opinion
peony Offline
Gold Star
peony
Joined: Mar 2013
Posts: 250
Just curious about what others are doing:

Are you going to be overdisclosing the fees in the no tolerance section on the Closing Disclosure to avoid eating the actual costs? Example: appraisal fee, credit report fee, etc.

There is a confusion about the real estate taxes. Will this go in the 'Any Increase Permitted' section or the 'No Increase Allowed?' I was thinking it would go in the 'Any Increase Permitted' because it is being paid to a third party, not us but I was told by another person that was not right and that it would go in the 'No Increase Allowed.' Any clarification?

Thanks in advance.

Return to Top
TRID - TILA/RESPA Integrated Disclosures Rule
#2038574 - 09/15/15 05:37 PM Re: Need other banks' opinion peony
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,388
Galveston, TX
How can you over disclose anything on the Closing Disclosure????

As far as property taxes go, it depends on whether they are considered prepaid or not.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2038575 - 09/15/15 05:44 PM Re: Need other banks' opinion peony
peony Offline
Gold Star
peony
Joined: Mar 2013
Posts: 250
I meant Loan Estimate - Oops!

Property taxes are usually paid at closing if they owe anything at the time.

Return to Top
#2038576 - 09/15/15 05:47 PM Re: Need other banks' opinion peony
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,388
Galveston, TX
Over disclosing estimates on a LE is not going to comply with the "good faith" standard as set forth in the regulations. If the regulators see that you are always over-disclosing with no apparent reason, I would guess you should expect a citation.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2038577 - 09/15/15 05:48 PM Re: Need other banks' opinion peony
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,388
Galveston, TX
For a discussion on property taxes, you might want to read this thread:

https://www.bankersonline.com/forum/ubbt...rty#Post1995627
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top