Regarding the 10% tolerance for recording fees, are the recording fees and fees charges by the settlement attorney all included in a cumulative 10% tolerance, or are recording fees in their own 10% tolerance category? For example, we have a settlement attorney that did not disclose they would be charging a $50.00 release fee on a refinance, however, we did over-disclose on the lenders title policy fee on the Loan Estimate, which will allow us to remain under the 10% tolerance if this is a cumulative tolerance.
For TRID purposes, is a construction loan considered to be a purchase money loan?
In regards to the new TRID disclosures, we choose not to issue the seller CD on a purchase transaction. Thus, we are not disclosing seller incurred fees on our borrower's CD. We are being told that this is incorrect and that we should be disclosing those fees. Again, this is seller incurred fees, not borrower fees that the seller paid. Your thoughts on this.
I just don’t understand how my appraiser is coming up with the cap rate he is using on an appraisal. What does he consider in his work-file to determine the cap rate used?
Are tiny homes subject to HMDA reporting?