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#2215408 - 06/11/19 04:43 PM Split fees - section H on CD?
Love those Regs Offline
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Joined: Apr 2002
Posts: 296
Southern State
Recent independent audit indicated on the closing disclosure that split fees for settlement / closing costs should be reported in Section H "Other" on the CD rather than in Section B (borrower did not shop). For clarification, if needed, split fees being borrower paid half and seller paid half. I have not been able to find any regulatory guidance to support that finding.
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#2215423 - 06/11/19 06:21 PM Re: Split fees - section H on CD? Love those Regs
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,225
Galveston, TX
Who pays for a fee has nothing to do with the placement of the fee on the CD. It all depends on the type of service provided and whether it is required or not and whether it is shoppable by the borrower.

Find a new auditor.
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