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#2236229 - 05/06/20 03:24 PM Reimbursements
Nicole Offline
100 Club
Joined: Nov 2018
Posts: 156
if you do not disclose a fee as prepaid when you should have. Do you reimburse the entire fee or just the amount you understated APR wise?

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TRID - TILA/RESPA Integrated Disclosures Rule
#2236230 - 05/06/20 03:26 PM Re: Reimbursements Nicole
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,219
Galveston, TX
It depends on what you are trying to do. Stop the regulators from ordering restitution or eliminate civil liability. Most lenders just kick the entire fee back - simple easy process - no guessing.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2236231 - 05/06/20 03:45 PM Re: Reimbursements Nicole
Nicole Offline
100 Club
Joined: Nov 2018
Posts: 156
so we can simply reimburse the fee that we disclosed incorrectly?

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#2236240 - 05/06/20 05:05 PM Re: Reimbursements Nicole
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,219
Galveston, TX
Yes - reimbursing them a fee that should have been treated as a prepaid finance charge will make the disclosure of the finance charges on the final CD correct.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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