We have been getting some flak recently from our secondary markets, about disclosing their names as the recipient of fees. My understanding has been that RESPA requires the ultimate recipient of the fee to be listed. (#4 Massachusetts Bankers Q & A)

Is this a new attempt at a loophole? Anyone else seeing this problem?

What type of fees are you talking about, and why don't your secondary markets want their names on the HUD-1?

Underwriting and tax service fees. I don't know any legitimate reason why they would not want us to show their charges on the HUD.

We list the secondary market investor as the one the fees are paid to and we haven't had any complaints.

Ditto here... until now. So why the sudden change? If they expect us to list our name as the recipient; then I say WE keep the fees. (that'll go over big)