Skip to content
BOL Conferences
Thread Options
#2252999 - 04/27/21 12:31 PM Closing Disclosures (CD)
Lizz Offline
100 Club
Joined: Aug 2013
Posts: 128
Dunkirk NY
We are getting many requests to move closings after we have completed the closing disclosure and documents. We came up with the following in an attempt to deter this practice and wanted to add the language to the commitment:

If, for any reason, a second set of closing papers must be prepared, a processing fee of $100.00 will be assessed.

My question – I assume we would need to redisclose, so would this charge be considered an APR fee and where should I disclose it?

Return to Top
TRID - TILA/RESPA Integrated Disclosures Rule
#2253005 - 04/27/21 01:13 PM Re: Closing Disclosures (CD) Lizz
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
If they are paying you, then Section A. If they are paying a third party - then Section B.

I would say this is a finance charge as it appears to be a penalty charge and not an actual document preparation charge.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2253012 - 04/27/21 01:39 PM Re: Closing Disclosures (CD) Lizz
Lizz Offline
100 Club
Joined: Aug 2013
Posts: 128
Dunkirk NY
Okay, Thank you!!

Return to Top
#2253021 - 04/27/21 02:36 PM Re: Closing Disclosures (CD) Lizz
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Be careful here! You cannot charge a fee for the preparation or delivery of the Closing Disclosure as part of those new closing papers. See Reg Z §1026.19(f)(5).
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#2253026 - 04/27/21 02:43 PM Re: Closing Disclosures (CD) Lizz
Jim Schue Offline
New Poster
Joined: Jan 2017
Posts: 21
In addition to the Reg Z concerns, this seems like the kind of fee assessment that would be inconsistently enforced.. Causing an entirely different set of problems.

Return to Top