If my bank originated a 2nd mortgage and it "absorbed" all costs, but the Closing Disclosure omitted the credit report cost paid-by-lender (about $10) and Courier fee paid-by-lender ($34).


Must such "minor" costs that are paid-by-lender be disclosed?

Thank you.

Yes. All costs paid in connection with the loan (and real estate transaction, if there is a seller), must be disclosed, even if the lender paid them. You should issue a revised closing disclosure.

Thanks John!

Well, it is a non-correctable violation, so a re-disclosure at this point is really a business decision.

Randy is right. All the revised closing disclosure would do is provide some marginally useful information to the borrower. A retained copy of the revised closing disclosure will show an auditor/examiner that you caught a violation and attempted to fix it. It could be the one thing in the file that catches the auditor's/examiner's eye. That could be a good thing, or not.

We use to consider "mortgage processing fee" and "Satisfaction Processing Fee" as overhead but I'm thinking that they should be disclosed on the CD. The mortgage processing fee is to electronically record the mortgage and the same would be for the satisfaction processing fee. Although, the satisfaction processing fee would be related to the loan we are paying off. Should either of these be disclosed on the CD? Thanks!

What do you mean "overhead" - if the bank is not charging them in Section A and they would normally go to the bank - what is the point? I guess I am confused?

These fees are paid to a third party. As far as "overhead", we just never passed those fees on to the borrower.

Then from day one of TRID they were required to be disclosed in the "paid by others" column on the borrower's CD.