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#760440 - 06/25/07 10:11 PM settlement charges
parr04 Offline
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Joined: Aug 2004
Posts: 394
oklahoma
Are we required to list items such as credit report fees on the GFE?. I would not consider it a settlement fee.

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Lending Compliance
#760461 - 06/25/07 10:43 PM Re: settlement charges parr04
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,369
Galveston, TX
"I would not consider it a settlement fee."

Based on what? It is a specific line item on the HUD-1.
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#760695 - 06/26/07 02:00 PM Re: settlement charges rlcarey
parr04 Offline
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Joined: Aug 2004
Posts: 394
oklahoma
I agree its a line item on the HUD 1, but is it a true settlement cost?. What about credit life and or VSI insurance? They would be listed on the HUD 1 but would they be listed on the GFE because they are not a true settlement cost.?

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#760700 - 06/26/07 02:07 PM Re: settlement charges parr04
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,369
Galveston, TX
If it goes on the back of the HUD-1 and is required by the lender, then it has to be listed on the GFE if you know or suspect the borrower will be charged for it. See the definition of settlement service in the definitions to 3500.2. It is pretty all inclusive.
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#760759 - 06/26/07 02:38 PM Re: settlement charges rlcarey
parr04 Offline
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Joined: Aug 2004
Posts: 394
oklahoma

Thanks, I did review the definitions of "settlement" as stated in 3500.2 and would agree that ALL known cost would have to be listed on GFE. This is contrary to some opinions stated on this site before.

In the case of the credit life, if the decision to aguire it is made after the GFE is given, should we give a new GFE?

Your input is greatly appreciated.

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#760820 - 06/26/07 03:11 PM Re: settlement charges parr04
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,369
Galveston, TX
If it is an election made by the borrower and not a requirement of the loan - it should not be a problem.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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