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-The following issues arose during a recent audit, but would like a second opinion as the regs are rather fuzzy in regard to application and definition of certain terminologies. (Note: these questions have also been posed to HUD; so far no response)
1. Is a charge required to be disclosed on the GFE/HUD if not “typically” charged to the Borrower in our institution? Our Bank absorbs the flood and credit report charges in all cases.
2. FAQ HUD-1 1100 series #16 clarification: In terms of a cost (partial or otherwise) (i) paid by the seller on behalf of the borrower vs (ii) a separate charge to the seller each instance being disclosed differently on the HUD as referenced in #16 please advise as to the proper disclosure format, (i) or (ii), of the following scenarios: GFE disclosed entire settlement fee as paid by borrower – at closing borrower pays half and seller pays half. GFE disclosed half of settlement fee as paid by borrower – at closing borrower pays half and seller pays half.
3. Block 1 – #2, #7, #9 clarification “lender inspection”: Is the “lender inspection fee” considered to be a lender “Origination charge” if the service is performed by a third party and/or not performed at origination, rather staged during the term of the loan? This lender inspection fee is actually a follow up appraisal inspection for construction that has been completed and the borrower cannot select the provider. Thank you.
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