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#1790448 - 03/01/13 11:44 AM Extended Lock Fee Question
TINKerBell Offline
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TINKerBell
Joined: Nov 2006
Posts: 3,255
Tiger's Den!
For customers that need a longer lock term we offer an "extended lock" usually for loan scenarios where a house is being renovated or constructed. Since these locks are > 90 days we charge the borrower an up-front fee to guarantee that rate for the full lock term. There was some questions as to whether this was allowed under Dodd Frank's compensation plan policy. Is it still OK to charge the borrower the up-front fee for the extended lock period in our Retail Lending and Broker channels?
Thanks very much.
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Loan Originator Compensation Rule
#1790616 - 03/01/13 05:36 PM Re: Extended Lock Fee Question TINKerBell
TINKerBell Offline
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TINKerBell
Joined: Nov 2006
Posts: 3,255
Tiger's Den!
help?!? Is my question not clear enough?
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#1790619 - 03/01/13 05:38 PM Re: Extended Lock Fee Question TINKerBell
Dani York, CRCM Offline
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Dani York, CRCM
Joined: Apr 2005
Posts: 3,663
TN
They did not finalize the proposed restrictions on points and fees stating that they needed to do more research. So your rate lock fee is fine for now.
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#1790677 - 03/01/13 06:59 PM Re: Extended Lock Fee Question Dani York, CRCM
TINKerBell Offline
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TINKerBell
Joined: Nov 2006
Posts: 3,255
Tiger's Den!
Thanks Dani. I had that paragraph prepared as part of my response. But I was unsure if I was missing something, since I am not a RESPA/TILA subject matter expert.
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The last thing that blew my mind was the wind.

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