Good morning,

On a purchase deal, a borrower chose to have a pest inspection and a survey. We did not require the services. The title company is placing the 2 fees on line 1302 and 1303 (with a lump sum on line 1301 of the HUD. Then, on the 3rd page of the HUD, for comparison, they show the charge on the HUD side and $0.00 on the GFE side.

I do not agree with the HUD set up. My FI did not require these two services, nor did we disclose for it on the GFE(s). Could I request the Title Co to perhaps place these 2 charges in the 200 series? Any guidance would be appreciated. I didn't read anything pertaining to this circumstance in RESPA FAQs.

Thank you!

Items that are not a cost of getting the loan definitely do NOT belong on page 3 of the HUD.

I do think, however, that putting the fees on 1302 and 1303 is correct but they should NOT be totaled and shown on 1301 because they are not 'required services that you can shop for.' I would show the fees out in the borrower's column for each line. I wouldn't show them in the 200 section.

btw, the title company works for you so you don't have to 'request'. You can just tell them to do it the way you say. Remember, your bank is ultimately responsible for the docs, not the title company.

Hi Truffle Royale,

Thank you for the guidance...this makes perfect sense to me.
Yes, the title companies do forget that they are not responsible for the output of the HUD. I have to remind them quite often. This particular title company is trying to tell me that their software doesn't allow for line 1301 to not be lumped. I don't see how a title company would have software that doesn't allow for this type of change.

Thank you so much again!