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#2088123 - 07/14/16 09:15 PM Origination Fee Incorrectly Disclosed-Tol Cure?
ScoutLaRue Offline
Member
Joined: Jul 2016
Posts: 73
Our mortgagebot system incorrectly disclosed an incorrect (lower) the Freddie fee or we label it--origination fee on the LE. We have a call into them to find out why or how...in the meantime...

Do we need to charge the actual correct (higher) fee to the borrower on the CD, but issue a tolerance cure to the borrower for the difference at closing? So essentially, paying the borrower for our error--and then also paying the fee to Freddie...
or
Can we only charge what the mortgagebot incorrectly disclosed...and then eat the fee to Freddie only--but then couldn't an examiner ask why we are only charging .25% on this freddie loan, when Freddie's pricing shows we should actually be charging more?

Thank you everyone in advance!

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TRID - TILA/RESPA Integrated Disclosures Rule
#2088130 - 07/14/16 09:34 PM Re: Origination Fee Incorrectly Disclosed-Tol Cure? ScoutLaRue
Docs Offline
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Joined: May 2016
Posts: 241
Why not show the disclosed amount on the CD in the "Borrower Paid" at closing column and the excess in the "paid by others" column with the designation (L) for lender? The result is that the bank gets the disclosed amount from the borrower at closing and bank will pay the additional amount when they pay Freddie.
_________________________
Just my opinion, I could be wrong. - Dennis Miller

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#2088205 - 07/15/16 01:45 PM Re: Origination Fee Incorrectly Disclosed-Tol Cure? ScoutLaRue
ScoutLaRue Offline
Member
Joined: Jul 2016
Posts: 73
Thanks for your input @docs I've not done a tolerance cure that way before as they've just been a few dollars or cents here and there---this is quite a large amount and I have a feeling there may be a few more...

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#2088218 - 07/15/16 02:18 PM Re: Origination Fee Incorrectly Disclosed-Tol Cure? ScoutLaRue
totallyconfused Offline
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Joined: Jul 2016
Posts: 104
We usually do a cure as a lender credit we use compliance one though. I would wait a day or 2 to see if mortgage bot is going to reimburse though because then it would be a fee paid by others from mortgagebot.

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#2088241 - 07/15/16 02:46 PM Re: Origination Fee Incorrectly Disclosed-Tol Cure? ScoutLaRue
ScoutLaRue Offline
Member
Joined: Jul 2016
Posts: 73
@totallyconfused...I will inquire about a reimbursement from mortgagebot too..thanks!

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