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Past: For our HELOC loans, we used the HUD-1 as part of our opening disclosure to detail non-financing charges, andf the customer initiled this. We changed platforms and disclosures since then, but an auditor spotted the older ones and said we needed to re-disclose and refund the fees on them. Not many customers or big $$, but still confusing to customers who were informed of all charges in the proper timeline.
Do you agree that we need to do the refunds and redisclose on amounts known and not disputed?
If I understand correctly, you were using the HUD-1 to itemize fees for your HELOC transactions. As you know, HELOCs are exempt from RESPA and you aren’t required to use the HUD-1. With that said and based on the little information I have, I don’t think you have any reimbursement requirements or violations since HELOCs aren’t subhect RESPA. Your auditor might be concerned with potential liability under UDAAP or state law.
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