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#586589 - 07/21/06 02:46 PM LAR requeirments and RESPA
one of three Offline
Member
Joined: Jan 2006
Posts: 53
NJ
We are a DENOVO. We have an agreement with a Mortgage company they pay us a flat fee for each lead we send them. They close the loan in our name and then sell it within a week to a thrid party. Is this loan required to be on the LAR. Also does the fee need to be disclosed on the HUD 1?

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Lending Compliance
#586590 - 07/21/06 03:05 PM Re: LAR requirements and RESPA
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,530
Bloomington, IN
The entity making the credit decision reports the loan. See the broker rules in Appendix D of the A Guide to HMDA Reporting Getting it Right.

Do they only pay you the fee for the loans that are originated? If so, you have a Section 8 violation.

If they pay you for every lead, whether the lead originates or not, then that would be a "marketing" cost and I would think the fee would not need to be disclosed. However, I did not research this. I'm just speaking off the top of my head.
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The opinions expressed are mine and they are not to be taken as legal advice.

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