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#2131231 - 05/19/17 08:46 PM Construction Draw Fee
Compliance516 Offline
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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
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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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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
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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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#2143386 - 08/23/17 11:02 PM Re: Construction Draw Fee Compliance516
mdosu Offline
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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
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Galveston, TX
You mean like lien tracking? Same thing - APR fees.
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