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Properly disclosing fees

Question: 
Our software calculates the finance charge, the APR, the rate spread and the total of points and fees for us. Isn't our risk of a fee disclosure violation therefore very limited?
Answer: 

Your loan origination software (LOS) is only as accurate as the information entered in the system.
• The LOS calculates the finance charge and the APR based on fee information loaded into the system. You set up the charges and indicate whether a particular fee is a regular finance charge, a prepaid finance charge, or a fee that may be excluded from the finance charge. Placing a fee in the wrong category results in serious violations.
• The system calculates the total points and fees based on the fees entered into the system. You tell the system which fees are included in the calculation and which fees are excluded. Incorrect categorization leads to serious violations

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Learn more about Jack Holzknecht and Kelly Owsley’s webinar
Loan Fee Disclosures

First published on 04/23/2017

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