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#2175552 - 04/27/18 02:14 PM Total Loan Costs, Origination Charges, Disc Points
buckeyeben Offline
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Joined: Jan 2014
Posts: 33
We are primarily a TPO bank. Therefore, we charge the borrower an origination charge but the broker also gets payment most times from us in lender paid compensation. I'm receiving quite a few Q615-1 errors because the total loan costs are less than origination charges. My question is what happens if certain things show up in multiple areas in the calculation? For instance, our administration charge shows up as part of the amount in origination charges but also in total loan costs. Likewise, the points the borrower paid are showing up in the calculation of discount points, origination charges, and total loan costs. Is this accurate or is or system configuration need updated? All of the amount reported match how our CD looks but it just makes me question when values are showing up in multiple reporting buckets.

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#2175564 - 04/27/18 02:36 PM Re: Total Loan Costs, Origination Charges, Disc Points buckeyeben
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,370
Galveston, TX
If the broker compensation is in the Paid by Others column with an (L) designation, how can your total loan costs be less than the origination charges?
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#2175576 - 04/27/18 02:57 PM Re: Total Loan Costs, Origination Charges, Disc Points buckeyeben
Compliance NABW Offline
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Joined: Oct 2015
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Not sure what you exactly mean about the loan costs being less than origination charges, but, "Yes," you would definitely have certain charges showing up in different fields for HMDA reporting purposes. As these various fields are tied to the CD, with discount points as a good example, the amount for discount points would appear in the Discount Points field obviously, but would also show in the Origination Charges field, as it is located in Section A on the CD, and it would appear in the Total Loan Costs field, as Total Loan Costs include amounts in Section A.

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#2175621 - 04/27/18 04:39 PM Re: Total Loan Costs, Origination Charges, Disc Points buckeyeben
buckeyeben Offline
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Joined: Jan 2014
Posts: 33
Should our Lender Paid Comp not appear as part of the origination charge since we as the lender are paying this as a deduction in lender credits? Or should our lender paid comp be added into the total loan costs? I'm thinking option 1 but I could be wrong.

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#2175624 - 04/27/18 04:45 PM Re: Total Loan Costs, Origination Charges, Disc Points buckeyeben
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,370
Galveston, TX
Let's say you are charging the borrower a 1% origination fee - That appears in Line 2 of Section A as "Origination Fee" as paid by borrower.

If you are paying the broker .50% or half of the origination fee - That appears as "Broker Fee to ABC Mortgage Broker on Line 3 as Paid by Others (L).

I have no idea what lender credits have anything to do with this.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2175957 - 04/30/18 09:43 PM Re: Total Loan Costs, Origination Charges, Disc Points buckeyeben
buckeyeben Offline
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Joined: Jan 2014
Posts: 33
I'm sure I'm not explaining this correctly but since I have 2 LOS systems one is calculation the origination costs one way and the other is doing it different. So I will try to present it another way.
In LOS System 1 & 2 we have the exact same loan #123 where we charge $500 origination fee and the broker get lender paid comp of 2% of loan amount (example $100k loan - $2000 comp). Our $500 fee shows up in Box A under borrower paid at closing. The broker compensation ($2000) shows up Box A under Paid by Others (L). In LOS system 1 it is adding the two totals together as the origination charge of $2500. In LOS system 2 it is only showing our $500 fee as the origination charge. Which is correct?

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#2175960 - 04/30/18 10:07 PM Re: Total Loan Costs, Origination Charges, Disc Points buckeyeben
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,370
Galveston, TX
System 2 is correct. How is any amount Paid by Others included in "designated borrower-paid at or before closing"?

Paragraph 4(a)(18)—Origination Charges.
Enter, in dollars, the total of all itemized amounts that are designated borrower-paid at or before closing.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2175961 - 04/30/18 10:19 PM Re: Total Loan Costs, Origination Charges, Disc Points buckeyeben
buckeyeben Offline
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Joined: Jan 2014
Posts: 33
I completely agree but when you have 2 LOS systems giving you 2 completely different amounts it makes me take a step back. I read the exact same paragraph which made me think system 2 but then again I wanted to make sure I'm not missing some asterisk from the guide saying from a TPO standpoint it is acceptable.

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