I am reading the Joint Financial Regulatory Agencies proposed amendments to the recent passage of Prop 2 and have a question. In regards to the "actual "costs and refinance of the debt under Proposed section 153.45(2) it states "legislature intended the phrase "actual costs" to refer to costs that the lender actually incurs and requires the owner to pay back along with other advanced funds." This section is referring to the "limitation on the advance of additional funds" for the refinance loan.

Question is: actual costs = reimbursable costs? It appears from this blub that we would not be able to roll in an Origination Fee or Loan Commitment Fee as these are not identifiable reimbursable actual costs.

Has anyone read the "amendments" and have a different opinion?

Would be nice to have a home equity constitutional amendment that had no ambiguities, but I don't think it has happened in the 20 years since Texas began allowing home equity loans.