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#2087828 - 07/13/16 08:12 PM HELOC fees financed/ 1st stmt is wrong-?
Chocaholic Offline
Gold Star
Joined: Aug 2005
Posts: 443
Northwest
Ok we have to reimburse on a loan because the fees financed were not correctly shown on the initial periodic statement. I looked at the Joint Statement of Policy which is clear as mud... Also FIL 20-98 and the most recent exam handbook.... Anyone had any experience calculating reimbursements on these. My thought is we could just refund the fees and we would be good, but it seems to me since there is an accuracy tolerance we should take advantage of it at least.

Help would be appreciated.

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Lending Compliance
#2087885 - 07/14/16 01:50 AM Re: HELOC fees financed/ 1st stmt is wrong-? Chocaholic
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,219
Galveston, TX
Do you have an APR violation??
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