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Doc Prep Charges on the HUD1

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Question: 
Our Compliance Officer questions the placement of two items on the HUD1A and the GFE. Should the doc prep charge be placed in the section 800, items payable in connection with the Loan or under title charges, Item 1105. Our title Co states the difference is who prepares the docs. If the bank, it goes in 800 section, if an attorney or title co in title charges 1105. When placed in our doc software in 800 section it does not pass down to same line on GFE and HUD1A. Can you clarify the correct placement of the doc preparation charge?
Answer: 

Line 1105 is definitely the line for Document Preparation, but the general instructions for lines 1100 through 1113 state "This series covers title charges and charges by attorneys."

I agree with your Title Company. If you are charging a Doc. Prep. fee, it should be in the 800 series. If charged by the title company or an attorney, list it on line 1105. This is consistent with what I see in most banks and I have never seen it criticized by examiners.

First published on BankersOnline.com 9/22/03

First published on 09/22/2003

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Filed under compliance as: 

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