[kall14]

Our bank is considering implementing a wire fee for mortgage construction loans that will be assessed to the Home Builder and not the borrower.
Our builders for residential construction projects are provided the option to open an account for the funds to be transferred to once draws are requested and approved for funding by the borrower. Many of the builders have chosen to bypass the account option and request their funds be wired to their accounts at other banks.
We have wired free of charge to builders on construction loans for years. We would like to start charging for wires for builders that choose to not have a bank account to receive their funds.
The bank has drafted a Builder’s Wire Agreement for this purpose.
Are there any compliance concerns or TRID issues that may need to be considered?

[rcooper]

If you have a contract stating that the builder is responsible for the fee and not the responsbility of the borrower then it would not need to be disclosed on the LE/CD.

[rcooper]

If you have a contract stating that the builder is responsible for the fee and not the responsbility of the borrower then it would not need to be disclosed on the LE/CD.

[Author]

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