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#2067539 - 03/04/16 03:49 PM LE for purchase with simultaneous second
Cornfed Turtle Offline
Diamond Poster
Joined: Mar 2006
Posts: 1,323
"...Somewhere in Middle Americ...
Issuing LE for a home purchase. First will be a 30 year fixed rate conventional loan and the second will be a 15 yr ARM home equity product. Simultaneous close.

The LE for the first looks like all of our other LEs for purchases. The only thing that looked odd was the amount of the HE second is in "Adjustments and other credits." Checking on whether or not we moved that from "Funds from Borrower," but I'm getting off topic.....

The only fees on the HE are ones that cannot be shopped: the doc prep fee, the recording fee for the mtg, etc. But there is no fee disclosed for title work, which is typical on the seconds. Thinking that perhaps the title work on the first covered the title work on the second, but no. The fees for title services as outlined on the first mtg LE are slightly higher than usual due to the second and these fees are ones for which the customer can shop.

Questions:

~Should we be breaking these fees for second out and disclosing on the HE 2nd mtg LE? The discussion here is that the borrower, at this point, still has the option of closing the first and not the second. So why should we be disclosing
~ If it's OK to leave them where they are, does it make sense to attach the provider list to the 2nd mtg LE when there are no services listed in Section C?

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TRID - TILA/RESPA Integrated Disclosures Rule
#2067624 - 03/04/16 06:43 PM Re: LE for purchase with simultaneous second Cornfed Turtle
Compliance OK Offline
New Poster
Joined: Jun 2015
Posts: 15
Yes, I would say to request the amounts for the Title work amounts just for the First and then subtract them from the Title services that you were initially quoted for both loans. They should be separate, as you have two separate transactions. This would make the other question moot.

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#2067686 - 03/04/16 08:49 PM Re: LE for purchase with simultaneous second Compliance OK
Cornfed Turtle Offline
Diamond Poster
Joined: Mar 2006
Posts: 1,323
"...Somewhere in Middle Americ...
Drat! Appreciate your quick assistance though. The mortgage processing staff just won't be happy.

Found the other answer to section L on the threads, too. How awesome are we to each other?

Again, the answer is in conflict with the LE I'm holding, but ...... that's the way things have been rolling today.

Thanks again.

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