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#2067807 - 03/07/16 03:53 PM Are these settlement charges?
swiggles Offline
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swiggles
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Our customer is divorced but has never filed the divorce decree nor changed the title to the home to his name only. So now, in order to get clear title for a title policy, the title company filed the decree (fee), obtained a copy of the filed decree (fee) and filed a release from the ex-spouse (fee).

Are these settlement charges? Would these fees be part of the settlement agent's fees (for tolerance)? Would any of these be PPFCs for Reg Z APR?

I really have no idea. Help would be greatly appreciated.
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#2067812 - 03/07/16 04:05 PM Re: Are these settlement charges? swiggles
RR Joker Offline
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The Swamp
It all appears to be recording fees (not PPFCs) and (10%) and should qualify for a COC if need be due to the necessity to clear title.
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#2067818 - 03/07/16 04:36 PM Re: Are these settlement charges? swiggles
swiggles Offline
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The recording fees.....and we're talking over $200 of extra recording fees, are not fees necessarily required by us to perfect our lien. These are fees that the borrower should have paid and taken care of after his divorce. I don't see why the fees should be subject to any tolerances whatsoever.

Thoughts?
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#2067829 - 03/07/16 04:53 PM Re: Are these settlement charges? swiggles
RR Becca Offline
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out of the frying pan...
Well, my thoughts on it are that you probably won't close the loan without clear title, and these items are required to get clear title. Ergo, they are required in order to close the loan. Recording fees section, 10% tolerance applies.

I could be wrong...but you asked for thoughts. smile
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#2067830 - 03/07/16 04:56 PM Re: Are these settlement charges? swiggles
raitchjay Online
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OK
Right....recording fees are never unlimited tolerance...i agree with Joker and Becca. But i don't necessarily see reason for worry either, because as Joker says, this looks like an easy valid changed circumstance.
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