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#730267 - 05/11/07 12:25 PM Ranges of fees in HELOC ads
goingtoexperts Offline
100 Club
Joined: Jul 2006
Posts: 149
Good morning, the commentary in Reg Z 226.5[b](d)(8) states we are permitted to disclose property insurance is required without providing a fee range. If title insurance may be required on lines over a certain dollar limit, is it sufficient to state that fact and not supply a range for the fee (similar to propert ins.)? What about recording taxes which must be paid in certain states? Thanks!

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#731090 - 05/14/07 02:19 PM Re: Ranges of fees in HELOC ads goingtoexperts
Phoenix Offline
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Phoenix
Joined: May 2003
Posts: 832
southeast
Looks like the paragraph below the commentary you cited can cover you: "2. Itemization of third-party fees. In all cases creditors must state the total of third-party fees as a single dollar amount or a range except that the total need not include costs for property insurance if the creditor discloses that such insurance is required. A creditor has two options with regard to providing the more detailed information about third party fees. Creditors may provide a statement that the consumer may request more specific cost information about third party fees from the creditor. As an alternative to including this statement, creditors may provide an itemization of such fees (by type and amount) with the early disclosures. Any itemization provided upon the consumer's request need not include a disclosure about property insurance.

3. Manner of describing fees. A good faith estimate of the amount of fees must be provided. Creditors may provide, based on a typical or representative amount of credit, a range for such fees or state the dollar amount of such fees. Fees may be expressed on a unit cost basis, for example, $5 per $1,000 of credit."
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#731856 - 05/15/07 11:57 AM Re: Ranges of fees in HELOC ads Phoenix
goingtoexperts Offline
100 Club
Joined: Jul 2006
Posts: 149
Thank you. The early disclosures meet the requirements for disclosing fees as indicated above. An additional question. When advertising a HELOC, what verbiage is required in disclosures as it relates to title insurance and mortgage/recoding taxes? Must you disclose a range or is a statement that title insurance and mortgage/recording taxes are required under certain conditions sufficient? Thanks!! Have a great day!

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