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#2263070 - 12/01/21 08:13 PM Finance Charge Dispute
bean2 Offline
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Joined: Apr 2019
Posts: 167
The CD reflects a title charge- "document preparation fee" (section B, borrower picked from the creditor list)- The Settlement Statement reflects this fee as a "signing fee" for a POA, the fee is also listed under Title charges- The compliance department states the fee is a finance charge and should be included the finance charge calculation. The fee was not included and this loan is closed.

Section §1026.4(c)(7)(i)(ii)(iii). Charges excluded from the finance charge-- seems to indicate the fee may be excluded, however, I am not sure.

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TRID - TILA/RESPA Integrated Disclosures Rule
#2263076 - 12/01/21 10:12 PM Re: Finance Charge Dispute bean2
rlcarey Offline
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rlcarey
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Posts: 85,433
Galveston, TX
Without knowing specifically what a "signing fee" for a POA really means, it is impossible to say. What specific service was performed and was it a requirement of the lender?.
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#2263088 - 12/02/21 01:24 PM Re: Finance Charge Dispute bean2
bean2 Offline
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Joined: Apr 2019
Posts: 167
Unfortunately, I don't know exactly what the "signing fee" is. According to compliance, "pretty much everyone knows a signing fee is a finance charge". I will ask them to define it for me. Thank you!

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#2263095 - 12/02/21 02:15 PM Re: Finance Charge Dispute bean2
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 85,433
Galveston, TX
Call the title company and ask them specifically to explain that charge on that loan. Your Compliance Department is not going to know with any more certainty what is it for than you or I from that description. The real concern is that if this is NOT a fee for doc prep and that is the fee description you used on the CD, then you have additional problems.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2263117 - 12/02/21 04:12 PM Re: Finance Charge Dispute bean2
bean2 Offline
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Joined: Apr 2019
Posts: 167
Sorry I don't follow, "if this is a fee for doc prep and that is the fee description you used on the CD, then you have additional problems."

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#2263122 - 12/02/21 04:46 PM Re: Finance Charge Dispute bean2
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 85,433
Galveston, TX
Sorry - typo - I fixed it
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2263123 - 12/02/21 04:48 PM Re: Finance Charge Dispute bean2
bean2 Offline
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Joined: Apr 2019
Posts: 167
Ah! Thank you, yes that is another concern.

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