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#2110466 - 12/12/16 06:55 PM Disclosing a lender paid fee on the LE
Vive Accommodare Offline
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Vive Accommodare
Joined: Apr 2013
Posts: 581
Compliance
Would it be TRID-compliant if our company decided to not disclose a fee that we will cover? We don't charge the borrower for the tax service, however I want to be sure we are ok with not showing on the LE as the fee isn't imposed on the borrower.
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TRID - TILA/RESPA Integrated Disclosures Rule
#2110474 - 12/12/16 07:12 PM Re: Disclosing a lender paid fee on the LE Vive Accommodare
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,370
Galveston, TX
All fees associated with the closing of the loan must be shown on the CD regardless of who pays the fee.

Are these loans you are selling into the secondary market? If you are paying these fees in conjunction with the sale of the loan, that is a subsequent event and a matter of meeting the requirements of the sale into the secondary market. Those are not related to the loan transaction with the consumer. If these are portfolio loans, this fee should be shown as paid by lender on the CD.
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