Are monthly HOA dues required to be listed on the LE, page 1, Projected Payments, "Estimated Taxes, Insurance & Assessments" under "Other"?

We do not escrow for these fees.

Yes, and you have to list them even if you do not escrow for them. Those are the kinds of things that can make the escrow number different from the total in taxes, insurance & assessments.

Follow-up to the question above. How many months of HOA dues should be shown in Section H under Other Costs? Would we show an entire year, or only the number of months being collected from the buyer at the time of purchase?

I have tried to find the answer in the Reg itself, materials from the April Lending Triage Conference that covered TRID and other posts in the TRID Form, but am either blind or just not seeing any comments that address this question.

We received a worksheet from one of our branches located in another state (we have centralized loan doc prep for our loans) with all of the fees and figures associated with the loan application to create a LE. However, the person who filled out the form indicated how much the monthly HOA dues are, not an annualized figure. Want to make sure we disclose properly on our first official TRID covered application...

HOA dues shown in Section H are only "upfront" HOA dues, such as transfer or initiation fees. For us. this is not normally something we see in our area. And if we do, we never know about it prior to issuing the LE.

37(g)(4) Other.
4. Examples. Examples of other items that are disclosed under § 1026.37(g)(4) if the
1803
creditor is aware of those items when it issues the Loan Estimate include commissions of real
estate brokers or agents, additional payments to the seller to purchase personal property pursuant
to the property contract, homeowner’s association and condominium charges associated with the
transfer of ownership, and fees for inspections not required by the creditor but paid by the
consumer pursuant to the property contract.

Thanks MonicaMc. Our branch happens to know how much the monthly HOA dues are for the development where the customers are purchasing a residential lot. We won't always have a figure, but do in this case. I appreciate your help on this.

MonicaMc We have a purchase with HOA dues paid monthly. On the CD, where do we put these? I see above it says you only put them in Section H if they are like transfer or initiation charges. So you would put the actually monthly charge on page 3 under Due from Borrower at closing?

Chances are you will only be showing the monthly amount in with your other tax and insurance estimated payment section...unless something is actually due at closing regarding HOA.

Yes, you wouldn't put ongoing/monthly HOA dues in Section H. Section H still deals with closing costs, not ongoing monthly payments.

digging up an old thread because this just came up. So do "Dues" go in F or H? I've always put them in F, prepaids. Compliance Ease is giving is a fail for tolerance. I didnt think this was subject to tolerance.

Does anybody know for sure where HOA Dues go? Not HOA Cert, not trasnfer fees. But actual dues.

Thanks.

Section H - See 37(g)(4) Other - Comment 4. As state above, dues are not typically paid through closing, but if they are, it is a totally optional request by the consumer. Section F is reserved for those payments specifically required to be made by the creditor to close the loan.

That makes sense but so far the only matrices that I can find online that even have HOA Dues listed has them listed in F. One even said they needed the "(_months)"

http://www.lionbankdirect.com/sites/default/files/images/le_fee_placement_template_02.25.2016.pdf

37(g)(2) Prepaids.

1. Examples. Prepaid items required to be disclosed pursuant to § 1026.37(g)(2) include the interest due at consummation for the period of time before interest begins to accrue for the first scheduled periodic payment and certain periodic charges that are required by the creditor to be paid at consummation.

They are not "periodic charges that are required by the creditor to be paid at consummation".

Your matrix is saying that IF there are outstanding HOA dues that your bank requires to be paid at or before closing, then you'd show them in F. I've never had HOA dues that had to be shown as a prepaid. The only instance I could think of would be if there were back dues that the Association was going to put a lien against the condo. But again, I have never seen that.

I am not sure which specific matrix you are referring too - but yes - if they are actually required to be paid by the lender then that would be correct. I don't think that conflicts with anything I have previously communicated.

Matrix I posted says nothing of what Truffle is describing.

And This says

"Prepaid items required to be disclosed include the interest due at consummation for the period of time before interest begins to accrue for the first scheduled periodic payment and certain periodic charges that are required by the creditor to be paid at consummation.

Not...

"Prepaid items" are the interest due at consummation for the period of time before interest begins to accrue for the first scheduled periodic payment and certain periodic charges that are required by the creditor to be paid at consummation.

That doesn't sound like it excludes being able to put HOA Dues there. We put property tax installments in F. Does that qualify as your definitions of a prepaid?

There's no doubt you can put HOA in H, but Ive always known it to go in F, and was just wondering if it could go there. There shouldnt be any tolerance issue with it there.

I'm not going to argue how to read a matrix but it seems like you're going to argue the answers given here so I'm not sure exactly what else there is we can say. Maybe you should call your examiner for their answer.

Even rlcarey was confused by your post in regard to the matrix.

And nobody's arguing. I appreciate the responses but am I not supposed to give any feedback? ok. Message received.

I'll keep lookin'

Thanks everyone else.