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Refund of Rate Lock Fee - POC?

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Question: 
The rate lock-in fee payable to us and collected up-front by our affiliate bank is shown as POC on the HUD-1 at the construction perm closing. Do we need to show it as POC again on the HUD-1 at modification, since this is when the borrower will receive a refund of this fee in a check?
Answer: 

I'm not 100% clear on your process since you refer to the const/perm closing, which implies a one-time closing, but modifications do not require redisclosure. By the way, I assume you disclose the rate lock fee as a prepaid finance charge and include it in your APR calculations when you close the const/perm loan.

First published on BankersOnline.com 3/21/05

First published on 03/21/2005

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