Thread Options
#2174996 - 04/24/18 09:02 PM Lumped Fees?
MB Guy Offline
10K Club
Joined: May 2004
Posts: 10,124
Way, way south.
OK, I feel like I am in bizarro world right now. Do any of your banks or mortgage companies say that they're not charging the borrower for the credit report or flood determination but charge them an underwriting fee or origination fee? Hard to say we're not charging them for these fees when you go ahead and charge them an underwriting fee, and then everyone insists that it's OK to do the lumping of fees together. Maybe I've just read TRID wrong all this time?
_________________________
Giddy up.

Return to Top
TRID - TILA/RESPA Integrated Disclosures Rule
#2174997 - 04/24/18 09:07 PM Re: Lumped Fees? MB Guy
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 78,649
Galveston, TX
Can you do that - sure. Do you still have to disclose the charges and the payees as creditor paid - yes you do.

(f) Closing cost details; loan costs. Under the master heading “Closing Cost Details” with columns stating whether the charge was borrower-paid at or before closing, seller-paid at or before closing, or paid by others, all loan costs associated with the transaction, listed in a table under the heading “Loan Costs.”
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2175000 - 04/24/18 09:10 PM Re: Lumped Fees? MB Guy
MB Guy Offline
10K Club
Joined: May 2004
Posts: 10,124
Way, way south.
That's what I've read, not sure where they are getting their information. Thought I was missing something that allows them not to list out the fees/costs. Thanks Randy.
_________________________
Giddy up.

Return to Top
#2175001 - 04/24/18 09:13 PM Re: Lumped Fees? MB Guy
MB Guy Offline
10K Club
Joined: May 2004
Posts: 10,124
Way, way south.
OK, I found this in the TRID Guide:
Quote:
Services You Cannot Shop For are items provided by persons other than the creditor or mortgage broker that the consumer cannot shop for and will pay for at settlement.

So, if the customer/borrower is not paying for them at closing, then we don't have to list them?
_________________________
Giddy up.

Return to Top
#2175002 - 04/24/18 09:29 PM Re: Lumped Fees? MB Guy
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 78,649
Galveston, TX
Would the same apply then if the seller agreed to pay for the appraisal? Just not disclose it because the borrower is not paying for it?
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2175041 - 04/25/18 01:39 PM Re: Lumped Fees? MB Guy
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,654
The Swamp
I still don't show it and still consider it 'a cost of doing business' that will never be passed on to a borrower..on any loan, mortgage, other consumer, commercial, deposit, nothing.
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

Return to Top
#2175045 - 04/25/18 01:44 PM Re: Lumped Fees? MB Guy
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 78,649
Galveston, TX
Then I suggest that you ask the CFPB: https://reginquiries.consumerfinance.gov/

Not that I really disagree with either approach, but they are the only ones to settle this issue, because they have given less then stellar and consistent advice on this issue in the past.

Please report back smile
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2175056 - 04/25/18 01:56 PM Re: Lumped Fees? MB Guy
MB Guy Offline
10K Club
Joined: May 2004
Posts: 10,124
Way, way south.
Appreciate the responses, thanks.
_________________________
Giddy up.

Return to Top