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In a mortgage broker transaction is it a problem to include the delivery fees in the rate lock and disclose on line 801 origination fees on HUD? Should this be broken out further to show transparency to the borrower?
compliancegirl,
I’m not 100% sure what you mean by “delivery fees in the rate lock” but it does sound like it is something that would be included in the origination fee; which is disclosed in line 801. I don’t believe the FAQ’s, the regulation, or the RESPA Roundups address a fee with this specific title.
To provide for my transparency, you could breakdown what is included in the origination fee using the extra lines in the 800 series and not listing amounts for those fees outside of the columns.
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