We buy loans from other banks. The other bank is not showing the credit report, 4506T fee nor the employment verification fee anywhere, not on the LE nor on the CD. It is obvious the bank is paying these outside closing. The total is around $100.

Shouldn't these fees be shown and if the bank is paying them, provide a credit? Is the CD and LE out of compliance if these are not shown?

Thanks

If they are not fees either assessed to the borrower or the legal responsibility of the borrower, they do not have to be shown on the LE or CD.

You will find differing opinions on this. You might try searching something like "overhead" or "cost of doing business" in this forum. The opinions will range from disclose like we used to, to don't disclose on LE but show lender paid on CD or don't show at all.

I've gone with the last option on our small credit report fee that is never passed on.

Thanks to the group.

This may be another one of those "cleanup" issues that the Bureau should address when it gets around to housekeeping on these rules. What we don't want to see is one set of examiners (or even examiners from one region of an agency) saying you have to include everything and another one taking the more relaxed approach. These are the kinds of things nit-picking details that drive compliance officers to drink.