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#1346646 - 02/19/10 11:20 PM Quick GFE Question & Quick Reg Z Question
iliniyak Offline
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Joined: Jan 2008
Posts: 285
GFE: Can we charge a lower origination charge and rate than what was disclosed on the GFE? (If we waive a wire fee after the GFE has been issued)

REG Z: Do we need to include courier or wire fee as a finance charge if they are from the attorney paid for by the seller, when not a requirement of the bank as a condition of the loan?

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Lending Compliance
#1346654 - 02/19/10 11:48 PM Re: Quick GFE Question & Quick Reg Z Question iliniyak
Mrs. Rizzo Offline
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Mrs. Rizzo
Joined: Mar 2006
Posts: 10,392
Curled up by the fire...
GFE - Why are you doing this? Borrower requested?

Reg Z - Includes any charge payable directly or indirectly by the consumer and imposed directly or indirectly by teh creditor as a condition of or incident of the extension of credit.
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Take responsibility for your life.

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#1346710 - 02/20/10 02:40 PM Re: Quick GFE Question & Quick Reg Z Question Mrs. Rizzo
iliniyak Offline
Gold Star
Joined: Jan 2008
Posts: 285
Our lending officers quote a rate to our customers that is based on a pre-set range and loans over a certain dollar amount must approved by a laon committee at our institution (we keep all loans in house). Sometimes the GFE has to go out prior to the committee meeting. With that beign said, are we allowed to lower an origination charge or rate based on the committee's request and still be in compliance? (Doesn't adversely effect the borrower)

Thanks in advance to your response....

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#1346804 - 02/22/10 01:49 PM Re: Quick GFE Question & Quick Reg Z Question iliniyak
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
Fees in Block 1 can decreasee at settlement but they cannot increase.
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The opinions expressed are mine and they are not to be taken as legal advice.

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