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#827284 - 10/02/07 04:09 PM GFE redisclosure?
Pickles Offline
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Joined: Apr 2006
Posts: 275
Beach Bum, East Coast, USA
In requesting a breakdown of fees the title insurance company will be charging as a "closing fee", we discovered that California is charging a $25 Enviromental Protection fee. This fee was not reflected on the GFE that was provided to the client. I know that only 1 GFE is required to be provided, however, since it is a fee the client will incur, should a corrected GFE be sent?
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Lending Compliance
#827306 - 10/02/07 04:30 PM Re: GFE redisclosure? Pickles
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,533
Bloomington, IN
It's not required, but you are certainly free to re-disclose if you wish.

You do however have to be sure the fee is disclosed on the HUD Settlement Statement.
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#827316 - 10/02/07 04:38 PM Re: GFE redisclosure? Dan Persfull
Pickles Offline
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Joined: Apr 2006
Posts: 275
Beach Bum, East Coast, USA
thank you.... One more GFE question... We grant loans from $5,000 up to $3 million which creates a large range for title, appraisals, county and state taxes. Is there any regulatory requirement that prevents us from having such large ranges?
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#827341 - 10/02/07 04:55 PM Re: GFE redisclosure? Pickles
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,533
Bloomington, IN
Are you saying that you have a boiler plate GFE you give that shows costs ranges for loans from $5,000 to $3 million? If that's the case then I think you would have a difficult time justifying that you are giving a good faith estimate of charges.

Your GFE should reflect the cost, or range of costs, to the specific transaction.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#827355 - 10/02/07 05:07 PM Re: GFE redisclosure? Dan Persfull
Pickles Offline
Gold Star
Joined: Apr 2006
Posts: 275
Beach Bum, East Coast, USA
The line of business wants to consolidate 2 GFE's into one.. My agrument is the same as your response.. "How is that a Good Faith estimate of costs the client could incur"... thanks for the timing response...
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