Reg Z - Itemization exempt

Posted By: tuma

Reg Z - Itemization exempt - 08/15/03 09:56 PM

We are receiving some audit exceptions for incomplete Reg Z Itemizations on Res Mtg Loans we have originated and sold. My understanding has always been if the loan is subject to RESPA, and RESPA disclosures given, that the itemization is not required. In our TIL we give at closing we state "Per HUD-1 Settlement Stmt" or something similar in the Itemization area. My reading of Supplement I, Paragraph 18(c)4 confirms this to me. Does anyone else have a different understanding of this?
Posted By: David Dickinson

Re: Reg Z - Itemization exempt - 08/15/03 10:26 PM

You're correct. You DO NOT have to itemize the amount financed if you give a GFE and HUD-1/1A. See footnote #40 [§226.18(c)(1)] and the commentary to §226.19(a)(1)#5.
Posted By: tuma

Re: Reg Z - Itemization exempt - 08/16/03 12:31 PM

Thanks.
Posted By: Richard Insley

Re: Reg Z - Itemization exempt - 08/16/03 03:09 PM

Schedule your auditors for remedial Reg. Z training. If they're "catching" things like this, what are they missing?