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#2085884 - 06/29/16 03:51 PM Missouri - 1st Lien Loan Fees
hsimmers Offline
100 Club
Joined: Sep 2008
Posts: 124
Does anyone have any first hand guidance or have you been criticized for additional fees on 1st lien loans made under federal preemption. I'm thinking for separate Underwriting Fee, Wire Fee, E-recording fee. We have always shied away from charging any additional fees on both 1st and 2nd lien loans, but we are getting a lot of pressure since the fees are charged on secondary market loans.

any feedback is greatly appreciated!

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#2085901 - 06/29/16 04:39 PM Re: Missouri - 1st Lien Loan Fees hsimmers
GrBo1006 Offline
100 Club
Joined: Apr 2013
Posts: 106
Thats a difficult question. As large as MO is, there are multiple market segments. We exist in several of them. We back up any fees with statistical analysis of what is being charged in that market. So far, no issues with this practice.

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#2085915 - 06/29/16 04:59 PM Re: Missouri - 1st Lien Loan Fees hsimmers
hsimmers Offline
100 Club
Joined: Sep 2008
Posts: 124
So you split those out as itemized fees, correct? We had been advised to lump them in origination and not itemize the fees out, but we are looking to do that with some on 1st lien loans. We know we aren't able to on 2nd loans, at least that's the way the Bank has interpreted Missouri law thus far.

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#2085916 - 06/29/16 05:00 PM Re: Missouri - 1st Lien Loan Fees hsimmers
GrBo1006 Offline
100 Club
Joined: Apr 2013
Posts: 106
We split them out.

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#2086546 - 07/05/16 01:49 PM Re: Missouri - 1st Lien Loan Fees hsimmers
NoJustNo Offline
100 Club
Joined: Oct 2013
Posts: 221
Midwest
Take a look at 408.052. You can charge bona fide fees for necessary services. You should be itemizing the fees.

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