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#1528677 - 03/30/11 01:25 PM Initial HELOC Statement
ComplianceJungle Offline
Junior Member
Joined: Aug 2007
Posts: 40
We are trying to resolve an issue with our software vendor. They are not including the flood determination fee, recording fees, etc... under the fee section of the initial periodic statement for a HELOC. My interpretation of "fee" includes these items and I believe they shold be listed under that section. Can anyone help steer me in the correct direction?

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#1529232 - 03/31/11 01:05 AM Re: Initial HELOC Statement ComplianceJungle
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 80,815
Galveston, TX
I take it these fees are being paid out of the first advance on the line?? Do you mean "other charges" as I am not familiar with a "fee section"?

Paragraph 7(a)(6)(ii).

1. Identification. In identifying any other charges actually imposed during the billing cycle, the type is adequately described as late charge or membership fee, for example. Similarly, closing costs or settlement costs, for example, may be used to describe charges imposed in connection with real estate transactions that are excluded from the finance charge under 226.4(c)(7), if the same term (such as closing costs) was used in the initial disclosures and if the creditor chose to itemize and individually disclose the costs included in that term. Even though the taxes and filing or notary fees excluded from the finance charge under 226.4(e) are not required to be disclosed as other charges under 226.6(a)(2), these charges may be included in the amount shown as closing costs or settlement costs on the periodic statement, if the charges were itemized and disclosed as part of the closing costs or settlement costs on the initial disclosure statement.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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