Thread Options
#2116396 - 01/31/17 11:05 PM Showing Application Fee on Closing Disclosure
gcompliance Offline
New Poster
Joined: Dec 2016
Posts: 11
A result of a recent audit indicates that the application fee the borrower paid upfront cannot be listed on the CD in Section L but instead should be on page 2 as Borrower Paid Before Closing column. However if I list that application prepaid fee in that column it does not give credit against the cash to close figure. This is not a Lender Credit but the customer giving us a fee to process the application and it does not go against any particular fee. How are you displaying that fee.

Return to Top
TRID - TILA/RESPA Integrated Disclosures Rule
#2116398 - 01/31/17 11:21 PM Re: Showing Application Fee on Closing Disclosure gcompliance
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 78,948
Galveston, TX
So you make them pay an application fee after receiving the intent to proceed from the customer. If they pay it upfront, why do you think it should impact cash-to-close? They already paid it.

And welcome to BOL smile
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2116403 - 01/31/17 11:31 PM Re: Showing Application Fee on Closing Disclosure gcompliance
Darth HMDA, CRCM, CAMS Offline
Diamond Poster
Darth HMDA, CRCM, CAMS
Joined: Dec 2013
Posts: 1,387
CA
We would mark this in Section A as POC. It should not impact cash to close.

You are collecting the application fee after Intent to Proceed is obtained, correct? (Just checking!)

And as Mr. Carey said, welcome to BOL.
_________________________
The opinions expressed are mine, do not represent the opinions of my employer, and they are not to be taken as legal advice.

Return to Top
#2116445 - 02/01/17 03:38 PM Re: Showing Application Fee on Closing Disclosure gcompliance
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,593
Cape Cod
It's not a POC entry. It is a Borrower-paid before closing entry. It adds into the total of borrower closing costs, but is subtracted from cash to close in the second line of the standard calculating cash to close (CCC) table or the third line of the alternative CCC table for transactions without a seller.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#2116447 - 02/01/17 03:39 PM Re: Showing Application Fee on Closing Disclosure gcompliance
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,593
Cape Cod
And let me join the chorus -- Welcome to BankersOnline's forums, gcompliance.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#2116525 - 02/01/17 06:02 PM Re: Showing Application Fee on Closing Disclosure gcompliance
gcompliance Offline
New Poster
Joined: Dec 2016
Posts: 11
We do not collect the application fee until we have an Intent to Proceed. It is not a separate fee but used as a credit towards the closing cost at the end.

Return to Top
#2116607 - 02/01/17 09:28 PM Re: Showing Application Fee on Closing Disclosure gcompliance
Compliance NABW Offline
Diamond Poster
Joined: Oct 2015
Posts: 1,587
Not quite sure where you are going with the last statement. Did you collect anything from the borrower prior to closing or not?

Return to Top