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Good afternoon,
A HELOC does not require a Closing Disclosure and under RESPA, the use of a HUD statement is exempted for open-end lines of credit (HELOC). Under RESPA, it states there is no objection to the use of the HUD statement in which its use is not legally required. All settlement agents prepare a HUD statement for HELOCs. My question is if a HUD statement is used for a HELOC transaction, and the bank pays the credit report fee, does it matter whether the credit report fee is disclosed as paid by the bank or left blank on the HUD statement?
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