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#2215408 - 06/11/19 04:43 PM Split fees - section H on CD?
Love those Regs Offline
Gold Star
Joined: Apr 2002
Posts: 290
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.
Opinions are mine and subject to change frequently

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TRID - TILA/RESPA Integrated Disclosures Rule
#2215423 - 06/11/19 06:21 PM Re: Split fees - section H on CD? Love those Regs
rlcarey Offline
10K Club
Joined: Jul 2001
Posts: 78,967
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.
The opinions expressed here should not be construed to be those of my employer:

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