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#2249667 - 02/24/21 04:19 PM Reverse Mortgages - Lender Credits
CMSIngenue Offline
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Joined: Jan 2013
Posts: 150
We would like to apply a lender credit to an understatement of a fee on a reverse mortgage. We want to apply a specific lender credit to the fee that was under-disclosed. The investor is asking us to disclose as a general credit. Can someone refer me to guidance on what is the correct way to disclose the fee on an understatement? The investor is not being helpful in explaining why they want it this way.

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Lending Compliance
#2249678 - 02/24/21 04:55 PM Re: Reverse Mortgages - Lender Credits CMSIngenue
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,633
Galveston, TX
If they are buying the loan, why would you care - they are buying any compliance risk. Not to mention I have no idea anymore how the two different types of lender credit would even be reflected on a HUD-1? After almost 6 years into TRID - the HUD-1 has been blanked out of my mind.
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#2249683 - 02/24/21 05:21 PM Re: Reverse Mortgages - Lender Credits CMSIngenue
Inspector Offline
Gold Star
Joined: Apr 2016
Posts: 269
This sounds like a tolerance cure? If so, and if this link works, the RESPA FAQs describe the different ways that this can be disclosed. https://www.hud.gov/sites/documents/DOC_12618.PDF.

If the link doesn't work, just do a web search for "New RESPA Rule FAQs." Yes, referring to it as new is ironic.
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Opinions expressed are my own and do not reflect legal advice or the opinions of my employer.

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