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RESPA Management Questions on GFE

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Question: 
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 more in fees.<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 GFE line would the credit be reflected on?</ol>

First published on 05/06/2013

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