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#2153544 - 11/14/17 09:13 PM Whole number for Total of Interest Paid
Bec Offline
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Bec
Joined: Jul 2010
Posts: 1,114
The Great White North
Our Loan Origination Software will take the total of interest paid for the life of loan and round it up to a whole dollar amount and then calculate the TIP from there. Is this acceptable. While I don't find any guidance regarding this in 1026.37(l), there is some mention of minor variations in 1026.17. But that addresses whole cents, not dollars, is that the same?
1. Minor variations. Section 1026.17(c)(3) allows creditors to disregard certain factors in calculating and making disclosures. For example:

i. Creditors may ignore the effects of collecting payments in whole cents. Because payments cannot be collected in fractional cents, it is often difficult to amortize exactly an obligation with equal payments; the amount of the last payment may require adjustment to account for the rounding of the other payments to whole cents.
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TRID - TILA/RESPA Integrated Disclosures Rule
#2153565 - 11/14/17 10:16 PM Re: Whole number for Total of Interest Paid Bec
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,926
Galveston, TX
I have a hard time believing that less than a dollar is going to impact the TIP?
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2153570 - 11/14/17 10:38 PM Re: Whole number for Total of Interest Paid Bec
Bec Offline
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Bec
Joined: Jul 2010
Posts: 1,114
The Great White North
It appears that it is affecting the third decimal in our disclosures to trying to calculate them out with a mortgage calculator. Not seeing a lot of risk, but it is technically underdisclosing?
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#2153574 - 11/14/17 11:00 PM Re: Whole number for Total of Interest Paid Bec
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,926
Galveston, TX
There are no specific tolerances for the TIP disclosure, but I really don't understand why an LOS system would be doing that.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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