If you don't show the credit on the comparison chart to bring the tolerance to within the 10% allowable how will an auditor know you gave the correct dollar amount on page 1? Putting the credit on page 1 is only showing half of "your work". I am meeting the RESPA requirement of refunding the dollar amount over the 10 % allowed but is it really a violation to show the credit on page 3?
Go to www.hud.gov/respa. On the right side of the page you will see a link that says "Watch the Webcast". It is a webcast that HUD did in March 2010. In it, they specifically state that they are correcting the FAQ mentioned above and that the comparison chart should show the violation.
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