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#2149569 - 10/12/17 01:00 PM Overcollection of fee by cents
Vive Accommodare Offline
Gold Star

Registered: 04/11/13
Posts: 365
Loc: Compliance
If we have a charge for the upfront mortgage insurance premium, but we accidentally over collected by a penny do we have to reimburse for the penny?
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"Tact is telling someone to go to [censored] in such a way, they look forward to the trip" Winston Churchill

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TRID - TILA/RESPA Integrated Disclosures Rule
#2149573 - 10/12/17 01:18 PM Re: Overcollection of fee by cents [Re: Vive Accommodare]
John Burnett Offline

10K Club

Registered: 10/27/00
Posts: 36288
Loc: Cape Cod
There isn't any "de minimis" exception to the requirement that you pay back any amount that you "over collected."
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John S Burnett
BankersOnline.com
Professional Compliance Nerd since 1976.

"Illegitimi non carborundum"

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#2149594 - 10/12/17 02:03 PM Re: Overcollection of fee by cents [Re: Vive Accommodare]
Vive Accommodare Offline
Gold Star

Registered: 04/11/13
Posts: 365
Loc: Compliance
That was my fear!
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"Tact is telling someone to go to [censored] in such a way, they look forward to the trip" Winston Churchill

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