Thread Options
#2175249 - 04/25/18 08:18 PM TRID DISCLOSURE -NO ORIGINATION FEES
ledfoot Offline
Member
Joined: May 2004
Posts: 93
Georgia
A customer has run into unexpected construction costs on his home. The lender is wanting to make him an additional loan for these costs but does not want to charge any origination costs to him. What is the proper way to disclose this on the LE and CD? Do you just not put any fees on them or do you disclose what would normally be charges and then show a lender credit for them?
Please advise!
_________________________
Ledfoot

Return to Top
TRID - TILA/RESPA Integrated Disclosures Rule
#2175250 - 04/25/18 08:20 PM Re: TRID DISCLOSURE -NO ORIGINATION FEES ledfoot
raitchjay Offline
Power Poster
Joined: Oct 2009
Posts: 8,668
OK
Just don't put an origination charge.
_________________________
I'm fixin' to fix that.

Return to Top
#2175251 - 04/25/18 08:24 PM Re: TRID DISCLOSURE -NO ORIGINATION FEES ledfoot
raitchjay Offline
Power Poster
Joined: Oct 2009
Posts: 8,668
OK
It has never made any sense to me for a lender to "credit" themselves for a fee the bank (not some 3rd party, but the bank itself) isn't charging.
_________________________
I'm fixin' to fix that.

Return to Top
#2175252 - 04/25/18 08:26 PM Re: TRID DISCLOSURE -NO ORIGINATION FEES ledfoot
ledfoot Offline
Member
Joined: May 2004
Posts: 93
Georgia
Makes sense to me but just wasn't sure if there was something I was overlooking in RESPA or/and Reg Z.
_________________________
Ledfoot

Return to Top
#2175254 - 04/25/18 08:29 PM Re: TRID DISCLOSURE -NO ORIGINATION FEES ledfoot
raitchjay Offline
Power Poster
Joined: Oct 2009
Posts: 8,668
OK
I don't think you're overlooking anything. We have loans here frequently with no origination charge (say an internal refi with no new money, so that we got the origination charge already on the first loan)......we simply don't have an origination charge. It's as simple as that IMO.
_________________________
I'm fixin' to fix that.

Return to Top
#2175336 - 04/26/18 03:16 PM Re: TRID DISCLOSURE -NO ORIGINATION FEES ledfoot
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,544
Cape Cod
Including the costs and an offsetting lender credit would probably cause your LOS to count the costs (or some of them) as PPFCs and goose the APR up. That would be an inaccurate disclosure because it would not reflect the terms of the loan agreement, which did not include those costs.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top