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#1889888 - 01/24/14 01:35 PM EasyLender
lrocha Offline
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Joined: Mar 2011
Posts: 23
Does anyone use Eastlender as their origination system? My question is if we use a Title company as an affiliate the rule for section 43 HPCT points and fees test we need to include the Title companys portion of the premium to the finance charge. Does anyone know where this goes in the system?

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#1889892 - 01/24/14 01:44 PM Re: EasyLender lrocha
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
This is basically the same question that you asked in the other forum:

http://www.bankersonline.com/forum/ubbth...590#Post1888590

I'm not sure how many ways we can say that whether or not a fee is counted in the points and fees test and whether or not a fee is a finance charge are two very separate things. If you are trying to code the portion of the title insurance that your affiliate keeps as a finance charge, you are going down the wrong road. You need to visit with your vendor on how to code fees for finance charges and the points and fees test, as they are not the same thing.
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