Skip to content
BOL Conferences
Thread Options
#329042 - 03/03/05 06:20 PM Refund vs. Restitution
Lavender Offline
Gold Star
Lavender
Joined: Jun 2003
Posts: 335
On a HELOC, can we refund fees in lieu of sending out a new ROR?

Return to Top
Lending Compliance
#329043 - 03/03/05 06:49 PM Re: Refund vs. Restitution
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,533
Bloomington, IN
What happen that makes you think you need to refund and that you have a ROR problem?
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

Return to Top
#329044 - 03/03/05 06:53 PM Re: Refund vs. Restitution
Lavender Offline
Gold Star
Lavender
Joined: Jun 2003
Posts: 335
The closing costs were lower than disclosed/anticipated.
_________________________
Teamwork...Together we achieve the extraordinary!

Return to Top
#329045 - 03/03/05 07:01 PM Re: Refund vs. Restitution
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,533
Bloomington, IN
Just send the the borrower a nice little thank you letter and advise them that the costs came in lower than anticipated and you are returning the overpayment. Nothing else needs to be done.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

Return to Top
#329046 - 03/03/05 07:04 PM Thanks Dan!
Lavender Offline
Gold Star
Lavender
Joined: Jun 2003
Posts: 335
*
_________________________
Teamwork...Together we achieve the extraordinary!

Return to Top

Moderator:  Andy_Z