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#2146000 - 09/14/17 12:49 PM Average charges
Bville Offline
Diamond Poster
Bville
Joined: May 2001
Posts: 1,282
Out West
I am aware of the rules for using average charges for loan subject to TRID. Are there average rules for other types of loans?

Sometimes we overnight loan documents to borrowers and we don't know what the charge will be prior to mailing the documents. What is the best way to handle this if we choose to charge the borrower for the overnight fee?

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Lending Compliance
#2146005 - 09/14/17 01:20 PM Re: Average charges Bville
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 84,347
Galveston, TX
You can charge whatever you want on non-RESPA related loans subject to any State limitations.
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#2146042 - 09/14/17 02:52 PM Re: Average charges Bville
Bville Offline
Diamond Poster
Bville
Joined: May 2001
Posts: 1,282
Out West
So if we charge $20 to the borrower to mail something that costs us $10 to mail it's not an issue?

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#2146097 - 09/14/17 05:01 PM Re: Average charges Bville
RR Joker Offline
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RR Joker
Joined: Nov 2002
Posts: 20,656
The Swamp
I would make sure I have real averages to back that up...even if it falls outside of RESPA [up charging], it could possibly considered a UDAAP.
Last edited by RR Joker; 09/14/17 05:02 PM.
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