Thread Options
|
#2054030 - 12/14/15 05:58 PM
Other charges on P&S Contract
|
Platinum Poster
Joined: Jul 2015
Posts: 542
Gorham, ME
|
Purchase and sales contract presented at time of application. Contract shows other fees that are part of the transaction (building inspection, oil pro-rations, etc.) So...
Does the LO make a good faith estimate of these charges and put on LE? If yes, how do we verify the fees to put on the CD?
_________________________
Tracey
|
Return to Top
|
|
|
|
#2054058 - 12/14/15 07:34 PM
Re: Other charges on P&S Contract
Tracey, CRCM
|
Platinum Poster
Joined: Jul 2015
Posts: 542
Gorham, ME
|
Thank you Monica. That is what we are doing as well, but getting some push back.
_________________________
Tracey
|
Return to Top
|
|
|
|
#2054323 - 12/15/15 09:14 PM
Re: Other charges on P&S Contract
Tracey, CRCM
|
10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
|
If they aren't loan costs (not required by the lender), list them in Section H. Provide a good faith estimate of the cost of each such fee. They won't be subject to a tolerance check.
_________________________
John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
|
Return to Top
|
|
|
|
#2054417 - 12/16/15 04:14 PM
Re: Other charges on P&S Contract
John Burnett
|
Member
Joined: Nov 2008
Posts: 78
Anywhere but here
|
What if contract wasn't provided until after the initial LE was provided? Are we required to re-disclose the LE for services requested by the borrower and to be paid by them per the contract? I thought if we didn't have the contract at initial LE, we don't disclose again once receiving the contract just for borrower requested fees that we don't require. I'm being told differently and wanted to double check. Thanks!
|
Return to Top
|
|
|
|
#2054419 - 12/16/15 04:19 PM
Re: Other charges on P&S Contract
Tracey, CRCM
|
Power Poster
Joined: Oct 2009
Posts: 9,110
OK
|
I'm with you; my understanding of it is the only time you're listing such fees that you aren't requiring is when you have the purchase contract in hand at time of issuance of the LE. We don't re-disclose upon later receipt of the contract.
_________________________
I'm fixin' to fix that.
|
Return to Top
|
|
|
|
#2054443 - 12/16/15 05:11 PM
Re: Other charges on P&S Contract
Tracey, CRCM
|
10K Club
Joined: Jul 2001
Posts: 83,396
Galveston, TX
|
I'm being told differently and wanted to double check. Tell whoever is telling you that, that it is they whom need to do some double checking
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com
|
Return to Top
|
|
|
|
#2054495 - 12/16/15 06:51 PM
Re: Other charges on P&S Contract
rlcarey
|
Member
Joined: Nov 2008
Posts: 78
Anywhere but here
|
rlcarey, I will do exactly that! Thanks for reassuring me. This leads to another question. Will we put this on the CD under "other" or ignore it since it wasn't on the LE? I haven't seen this exact question addressed.... that I remember anyway!
|
Return to Top
|
|
|
|
#2054579 - 12/16/15 10:00 PM
Re: Other charges on P&S Contract
Tracey, CRCM
|
10K Club
Joined: Jul 2001
Posts: 83,396
Galveston, TX
|
It would just go on the CD under other.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com
|
Return to Top
|
|
|
|
#2055954 - 12/29/15 02:25 PM
Re: Other charges on P&S Contract
Tracey, CRCM
|
Member
Joined: Nov 2008
Posts: 78
Anywhere but here
|
Can someone provide me citation for not re-disclosing the LE just because contract has now been provided showing additional services requested not required for the loan? This would be in cases where the LE was issued prior to having the contract. I know this is correct but we sell our loans on the secondary market and our lender is holding up funding on a loan stating we should have done a changed circumstance once the contract was provided. I have searched the CFPB website but can't locate what I need.
|
Return to Top
|
|
|
|
#2055969 - 12/29/15 03:01 PM
Re: Other charges on P&S Contract
Tracey, CRCM
|
Power Poster
Joined: Oct 2009
Posts: 9,110
OK
|
Those items in the contract would be unlimited tolerance items (the lender isn't requiring them). I'd be asking them where it says i have to re-issue. I'd just send them 19(e)(3) and ask them where it says i must re-issue for items in the contract received after issuance of the LE.
_________________________
I'm fixin' to fix that.
|
Return to Top
|
|
|
|
|
|