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Disclosing Credit Report Fees under RESPA

Answered by: 
Dan Persfull

Question: 
On April 12, there was <a href="http://www.bankersonline.com/compliance/guru2010/gurus_comp041210d.html">a question</a> concerning credit bureau reports and how to disclose them if the lender does not charge for a credit report. The answer was that it should be listed in Block 3 and a negative amount in Block 2. Which line would we check in Block 2? Why would this be shown as a negative amount on line 802, when the charge isn't for a specific rate but for a credit report? The answer didn't address the fact that the lender doesn't charge for a credit report. If we don't charge, do we still need to include it in Block 3?
Answer: 

This has been discussed to great length in the RESPA forum. If you review the requirements of RESPA, all charges have to be disclosed regardless who pays them. You may not pass the credit report cost to the borrower, but there is a cost for the credit report, which you pay; therefore, it has to be disclosed.

First published on BankersOnline.com 6/14/10

First published on 06/14/2010

Filed under: 
Lending
Filed under lending as: 
Credit Bureau
Credit Report
Fees
RESPA

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