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#2064433 - 02/16/16 04:19 PM Credit Report Fee - 0% Tolerance
mdog76 Offline
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Joined: Jan 2007
Posts: 645
Our lead MLO is wanting to state a higher charge for the credit report on the LE due to higher costs the bank is incurring i.e. supplemental reports and checkups for secondary market loans above the normal credit report charge. Since the credit report is a 0% tolerance category, is it going to be a problem if he continues to show what the credit report could be and then the charge comes in lower? I can see this becoming a problem with auditors and examiners possibly since its a 0% tolerance.

I hope that made sense.

Thank you.

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TRID - TILA/RESPA Integrated Disclosures Rule
#2064435 - 02/16/16 04:25 PM Re: Credit Report Fee - 0% Tolerance mdog76
raitchjay Online
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Joined: Oct 2009
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My gut response would be that each fee should be itemized, not lumped together as "credit report fee"; so if a supplemental report or secondary market checkup fee might apply, they can be quoted as their own stand-alone fee, then if not charged, they drop off, but they don't build any 'cushion' into your actual credit report fee. IOW, you can't/shouldn't quote a lump "credit report fee" with all the possible extras built in; quote them separately. JMO.
I'm fixin' to fix that.

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#2064438 - 02/16/16 04:33 PM Re: Credit Report Fee - 0% Tolerance mdog76
Truffle Royale Offline

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Joined: Jul 2003
Posts: 17,356
I disagree.
The 'soft pull' required for secondary is a second credit report whose fee is dependent on the first cbr.
We quote a sum that is sufficient for a joint first and second pull.
It always comes in slightly lower than what we quote.
As long as it's always just 'slightly' lower, than I don't see any problem with examiners.
fwiw, my examiners had no problem with this under RESPA so I don't forsee any issue under TRID either.

mdog76, you're supposed to make sure that what you quote is sufficient to cover the actual cost and you can't go back and add more when you get the actual cost. So what choice do you have but to use a rounded up average cost within reason?

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#2064445 - 02/16/16 04:57 PM Re: Credit Report Fee - 0% Tolerance mdog76
mdog76 Offline
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Joined: Jan 2007
Posts: 645
I can see where listing each charge out on the LE makes sense instead of listing one lump sum since it is a 0% tolerance. Seems that you have better "control" over the charges that way over a lump sum.

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