Here's the problem (s)
- we obtain a HUD Settlement statement on all of our construction (only) loans; even ones where the land is already owned and on loans to developers..which I guess is a good thing because we have discovered several things
- some borrowers were charged twice for title bring downs (one fee was in the 800 series payable to the bank & the other fee was payable to the settlement agent and listed in the 1100 series)
-for consumer loans the settlement agent fee was not listed on the HUD, but we still used "a settlement agent fee' in calculating the finance charge.
- we collected 'lenders inspection fees', but did not include in the finance charge
So, now that I know all of this because of seeing a HUD that was not necessary what do I do....get rid of the HUD?

What does your compliance officer say?

Either financing from us (re-apply) or from another lender.

Sorry, you gave the HUD, I think that now you are stuck with what it says and with what you disclosed.

How many do you have? Construction reimbursemenets are ugly!

oh my - I thought we would have had to commit to the perm financing; which we have not.

Unfortunately not. HUD wrote this pretty loosely for a situation like yours.