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#2131231 - 05/19/17 08:46 PM Construction Draw Fee
Compliance516 Offline
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Joined: Aug 2016
Posts: 44
Would a construction draw fee paid to the Bank go under Section A or B of the LE? Also, should the word "Title" be included in the fee description on the LE & CD when the customer pays the Title company when they take care of the construction loan draws?

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TRID - TILA/RESPA Integrated Disclosures Rule
#2131246 - 05/19/17 09:15 PM Re: Construction Draw Fee Compliance516
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,368
Galveston, TX
All fees paid to the bank go in Section A. Since construction inspection fees are for a future service, they would not have a "Title -" designation.
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#2143169 - 08/23/17 12:37 AM Re: Construction Draw Fee Compliance516
mdosu Offline
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Joined: Dec 2016
Posts: 33
To follow up on this, what if the fee is not collected at closing and collected throughout the life of the construction loan?

If it's not collected at or before closing, it shouldn't go on the LE/CD, correct?

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#2143173 - 08/23/17 10:38 AM Re: Construction Draw Fee Compliance516
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,368
Galveston, TX
Currently no - but under the new TRID amendments, those will be required to be disclosed on an additional page to the CD. Also, estimated inspection and handling fees for services performed after consummation always have to be calculated into the APR, as they are finance charges.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2143386 - 08/23/17 11:02 PM Re: Construction Draw Fee Compliance516
mdosu Offline
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Joined: Dec 2016
Posts: 33
rlcarey, thanks for the confirmation. That's how I understood the TRID amendments as well.

So while bank collect fees (inspection/draw) post consummation factor into finance charges and APR, what about title co related fees post consummation?
Last edited by mdosu; 08/23/17 11:04 PM.
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#2143387 - 08/23/17 11:30 PM Re: Construction Draw Fee Compliance516
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,368
Galveston, TX
You mean like lien tracking? Same thing - APR fees.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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