Thread Options
#2115468 - 01/25/17 03:21 PM Credit Report Fee
Dodge Offline
100 Club
Joined: Mar 2010
Posts: 239
The Bank absorbs the cost of the credit report fee. Currently, we disclose the credit report fee on the Loan Estimate with a Lender Credit in section J. Then on the Closing Disclosure we list the Credit Report fee as P.O.C by Lender.

We received notice that the credit report fee will be increasing soon. How will this work? Will we need to do a change circumstance on the Loan Estimate that are tied to the loans that are in process to disclose the new fee? Or give the customer two dollars at the closing since that will be difference between the new fee and old fee?

Can we just start excluding the credit report from the Loan Estimate and Closing Disclosure? I saw a discussion that stated that you could leave it off. Is that what everyone else is doing?

Return to Top
TRID - TILA/RESPA Integrated Disclosures Rule
#2115477 - 01/25/17 03:42 PM Re: Credit Report Fee Dodge
Truffle Royale Offline

10K Club
Joined: Jul 2003
Posts: 17,346
The change in fee is not a valid changed circumstance anymore than an increase in any other fee would be.
If you've already pulled the cbr for the loans in process, the old fee should still apply because the fee as you put it is 'increasing soon'.
We just had that happen here so we immediately started disclosing the higher amount on all LEs from the day we got notice.
You'll need to raise your lender credit too.

Return to Top
#2115491 - 01/25/17 04:54 PM Re: Credit Report Fee Dodge
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 79,368
Galveston, TX
Even if they under disclosed the fee and lender credit on the LE, since the lender is paying the fee anyway, the only impact is the specific lender credit would be higher. I don't see it as an issue.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top