What does anyone else say?
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Robert Marx
Opinions stated are not necessarily that of my employer.
As a result, amendments were made to "Z" so you could exclude some fees paid to 3rd partys if you didn't require their use or retain part of the fee. Done correctly, it is excludable.
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Andy Zavoina
Opinions stated are not necessarily that of my employer.
[This message has been edited by Andy Z (edited 01-15-2002).]
One of the results of the Rodash amendments was to put in place a tolerance level for certain types of loans. On your new real estate loans you have a $100 tolerance before you'd have a reimbursable violation. So in a way it is moot.
From the ABA Exec. Update, June 1996:
Exclusion of specific fees. Under the 1995 Legislative Amendments, the following fees are excluded from the finance charge with respect to mortgage transactions:
· Fees imposed by third-party closing agents that are neither requested nor retained by the lender (§ 226.4(a)(2));
· Fees for preparation of loan-related documents (§ 226.4(c)(7)(ii));
· Fees for pest infestations or flood hazards conducted prior to closing (§ 226.4(c)(7)(iv));
· Certain taxes paid as a precondition to recording an instrument securing the evidence of debt, if itemized and disclosed (§ 226.4(e)(3)).
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Andy Zavoina
Opinions stated are not necessarily that of my employer.
[This message has been edited by Andy Z (edited 01-15-2002).]