Following are 3 Q&A's from HUD's
New RESPA Rule FAQ's (9-18-2009). Is HUD talking out of both sides of its mouth, or is there a distinction here that I am missing? After reading these, I do not know whether to include the closing attorney's doc prep fee on 801 or 1101:
HUD-1 – 800 Series (Page 31)
1) Q: What charges are included in “Our origination charge” on Line 801 of the HUD-1?
A: Line 801 includes all charges received by a loan originator, except for any additional charge (“points”) for the interest rate chosen on the loan. The amount on Line 801 also includes all amounts received for any service, including administrative and processing services, performed by or on behalf of the lender or any mortgage broker. (The amount on Line 801 is not listed in the columns.)
2) Q: If an attorney prepares loan documents for a lender, where does that charge go on the HUD-1?
A: Loan document preparation done on behalf of the loan originator is a processing and administrative service in the origination of a loan and is included in the charge on Line 801 of the HUD-1, and may not be separately itemized.
HUD-1 – 1100 series (Page 34)
3) Q: Are document preparation fees included in “title services” or would they appear as separate line item charge in the borrower’s column?
A: Document preparation fees are part of administrative or processing fees which are included in the charge in Line 1101 of the HUD-1 and may not be separately itemized.
MarkB
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