Skip to content
BOL Conferences
Thread Options
#2195642 - 10/17/18 02:54 PM Seller Paid Origination Charges
K.D Offline
New Poster
Joined: May 2018
Posts: 16
Per Reg Z 2. Actual increase. A creditor may determine good faith under § 1026.19(e)(3)(i) and (ii) based on the increased charges reflected on revised disclosures only to the extent that the reason for revision, as identified in § 1026.19(e)(3)(iv)(A) through (F), actually increased the particular charge. For example, if a consumer requests a rate lock extension, then the revised disclosures on which a creditor relies for purposes of determining good faith under § 1026.19(e)(3)(i) may reflect a new rate lock extension fee, but the fee may be no more than the rate lock extension fee charged by the creditor in its usual course of business, and the creditor may not rely on changes to other charges unrelated to the rate lock extension for purposes of determining good faith under § 1026.19(e)(3)(i) and (ii).

My question is if the seller paid origination charge (Lock extension fee) was not updated on the final LE or the initial CD, can it be added on a revised CD? (The rate lock was requested by the seller)

My thought is that it is not a charge imposed on the consumer so we should be okay...

Thank you
Last edited by K.D; 10/17/18 02:55 PM.
Return to Top
TRID - TILA/RESPA Integrated Disclosures Rule
#2195643 - 10/17/18 02:57 PM Re: Seller Paid Origination Charges K.D
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
Correct
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2195644 - 10/17/18 02:57 PM Re: Seller Paid Origination Charges K.D
K.D Offline
New Poster
Joined: May 2018
Posts: 16
Thank you!!!

Return to Top