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#2054465 - 12/16/15 05:57 PM Missing Fees on the LE and CD
OldSchoolBanker Offline
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Joined: May 2005
Posts: 660
FL
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
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#2054474 - 12/16/15 06:27 PM Re: Missing Fees on the LE and CD OldSchoolBanker
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,268
Galveston, TX
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.
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#2054476 - 12/16/15 06:29 PM Re: Missing Fees on the LE and CD OldSchoolBanker
RR Joker Offline
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RR Joker
Joined: Nov 2002
Posts: 20,654
The Swamp
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.
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#2054550 - 12/16/15 09:14 PM Re: Missing Fees on the LE and CD OldSchoolBanker
OldSchoolBanker Offline
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Joined: May 2005
Posts: 660
FL
Thanks to the group.
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#2054556 - 12/16/15 09:18 PM Re: Missing Fees on the LE and CD OldSchoolBanker
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,629
Cape Cod
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.
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