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#2242160 - 09/08/20 10:47 PM Commercial loan disclosure
Wanna Know Offline
Junior Member
Joined: Aug 2018
Posts: 44
While preparing commercial loan documents, can you combine 3rd party fees with a lender fee? There is no breaking it down - just one fee that will be paid to various 3rd parties and the the bank will keep a portion of it. The borrower documents will state it is for "Disbursements".

Your thoughts????

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Lending Compliance
#2242171 - 09/09/20 01:09 PM Re: Commercial loan disclosure Wanna Know
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,219
Galveston, TX
If anything, it would be a State law issue and then you would have to worry about UDAAP, if how you are disclosing fees to commercial customers are deemed deceptive.
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