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#2249196 - 02/12/21 08:40 PM Verification of Employment fee
Cbigun Offline
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Joined: May 2016
Posts: 128
1026.38(f) states “For each transaction subject to § 1026.19(f), the creditor shall disclose the information in this section: ……..(f) Closing cost details; loan costs. Under the master heading “Closing Cost Details” with columns stating whether the charge was borrower-paid at or before closing, seller-paid at or before closing, or paid by others, all loan costs associated with the transaction, listed in a table under the heading “Loan Costs

Back when TRID came out the whole purpose was that every fee in connection with the loan had to summarized and disclosed, no matter who paid for it. So, my question is, if there is a Verification of Employment fee in connection with the loan, but the bank chooses to pay it as a "cost of doing business", does it have to be disclosed on the CD showing that the BANK paid it? Is that part of "all loan costs associated"?

I think I have this down and then the response is..... we don't pass it on to the borrower if we get charged.

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TRID - TILA/RESPA Integrated Disclosures Rule
#2249204 - 02/12/21 09:42 PM Re: Verification of Employment fee Cbigun
Dan Persfull Online
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Dan Persfull
Joined: Aug 2002
Posts: 46,287
Bloomington, IN

3. Fees “paid to” a person. For purposes of § 1026.19(e), a fee is not considered “paid to” a person if the person does not retain the fee. For example, if a consumer pays the creditor transfer taxes and recording fees at the real estate closing and the creditor subsequently uses those funds to pay the county that imposed these charges, then the transfer taxes and recording fees are not “paid to” the creditor for purposes of § 1026.19(e). Similarly, if a consumer pays the creditor an appraisal fee in advance of the real estate closing and the creditor subsequently uses those funds to pay another party for an appraisal, then the appraisal fee is not “paid to” the creditor for the purposes of § 1026.19(e). A fee is also not considered “paid to” a person, for purposes of § 1026.19(e), if the person retains the fee as reimbursement for an amount it has already paid to another party. If a creditor pays for an appraisal in advance of the real estate closing and the consumer pays the creditor an appraisal fee at the real estate closing, then the fee is not “paid to” the creditor for the purposes of § 1026.19(e), even though the creditor retains the fee, because the payment is a reimbursement for an amount already paid.
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The opinions expressed are mine and they are not to be taken as legal advice.

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