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#251099 - 09/30/04 05:47 PM Renewal Fee ROR
Norman Offline
Member
Joined: Jul 2004
Posts: 70
Wisconsin
Our bank is considering charging a $15.00 renewal fee for all renewed consumer loans. Will we need to give a Right of Rescission for consumer real estate renewals that are charged the fee?

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Lending Compliance
#251100 - 09/30/04 05:57 PM Re: Renewal Fee ROR
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
No. (assuming a no cash out refinance)
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The opinions expressed are mine and they are not to be taken as legal advice.

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#251101 - 09/30/04 06:56 PM Re: Renewal Fee ROR
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,393
Galveston, TX
And assuming that you are talking about closed-end credit
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#251102 - 09/30/04 06:57 PM Re: Renewal Fee ROR
Norman Offline
Member
Joined: Jul 2004
Posts: 70
Wisconsin
There is no new money other than the renewal fee of $15.00. This would be for a renewal of a loan not a refinance though. Does that make a difference?

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#251103 - 09/30/04 06:58 PM Re: Renewal Fee ROR
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,393
Galveston, TX
Refinances of closed-end credit by the same creditor with no new money does not trigger the RofR.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#251104 - 09/30/04 07:26 PM Re: Renewal Fee ROR
Norman Offline
Member
Joined: Jul 2004
Posts: 70
Wisconsin
Thank you both for your quick responses.

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#251105 - 10/20/04 03:12 PM Re: Renewal Fee ROR
SouthoftheBorder Offline
Gold Star
Joined: Feb 2002
Posts: 335
The South
How about renewals of open-end HELOCs with a fee of $150?

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