03/12/2017
In the event when a joint credit report is pulled for a joint application, but then the loan is restructured using only one of the borrowers and the credit report is unmerged to obtain only the individual borrowers credit data, can the lender collect the charge for both invoices from the borrower (the invoice for the original report and the invoice for the unmerge service)?
12/27/2015
When can you collect an appraisal fee for a HELOC?
07/26/2015
If you have a packaging fee that is charged to the customer on SBA loans would that be a fee that falls under FASB? Basically the fee is an origination fee but the SBA calls it a packaging fee.
10/13/2014
Can someone tell me if there is a limit on fees we can charge when a borrower changes insurance companies? We charge a rewrite fee.
04/21/2014
I noticed on invoices on CBC credit bureaus the company is charging additional fees besides the cost of running the credit bureau. The fees include items like a $9 charge to update credit bureau records. $55 charge for something called 3 system residential mortgage. The bank passes these costs on to the customer on the GFE as credit bureau fees when the actual cost of the running the bureau is ~ $20.90. Should the bank be passing the extra charges from CBC on to the customers which do not appear to be costs of the actual bureau? No other credit bureau service appears to be adding charges to their bills.
04/14/2014
When we are doing a modification to a 7 year balloon higher priced mortgage loan, can we charge the customer a modification fee?
07/01/2013
These are general RESPA questions that have recently been proposed by Management and we would appreciate your expertise.<ol><li>Do we have to itemize Hazard Insurance on the GFE for a home equity loan when the Hazard Insurance is already in place? It is my understanding this is a requirement on the GFE because we require the Hazard Insurance to be in place before making the loan therefore it is a cost of the loan.<li>If all the fees are paid by the lender except for the origination fee, do we need to itemize each fee paid by the lender on the GFE? Doing this gives the wrong impression to the customer that they will owe fees that they actually won't have to pay.<li>If your answer is yes to #2, could we show a credit on the GFE for the fees being paid by the lender? Doing so would bring the final fee disclosed to reflect the actual amount being paid by the customer. Another related-question would be what line would the credit be reflected on the GFE? </ol>
06/24/2013
What fees are required to be disclosed (if any) for a commercial loan? In the past, we have disclosed only the bank's fees. Some time ago we were told to disclose everything including title company fees. Which one is right?
06/24/2013
We are making a loan in the amount of $4500 for one year against the borrowers primary residence for the purpose of paying delinquent real estate taxes. The rate will be 7.50% and total fees will be less than $528. The loan is not an HPML, but what about HOEPA? The APR will be over the 8.00% plus treasury but my fees will be less than $528.00. Is there any threshold for a loan amount to be exempt from HOEPA. Please advise.
06/17/2013
A seller is paying closing costs to the buyer. Do these closing costs need to be identified since some are APR fees and others are not? Can the lender issue a credit toward a portion of discount fees on the HUD1? Since origination and discount fees are APR fees, does the APR need to be reduced by the amount of the credit? Can the APR be over-stated by more than .125 since this is the borrower's benefit?