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We are working on offering a new product at our bank for a “no-cost” loan. I have the HUD filled out showing the fees and the credit given in line 802 according to the RESPA FAQ’s. My question is on the Disclosure Statement and the “Amount Financed Itemization” section at the bottom. This would also be on the Disbursement Request and Authorization. Should the fees the bank is paying as the “no-cost” part be there?
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The itemization of the amount financed only includes amounts included in the loan amount. That would not include fees you paid on the borrowers behalf. I am not familiar with your Disbursement Request and authorization. That is not a required by federal law. You should discuss that form with your loan origination software vendor, or perhaps another bankers familiar with the form can supply an answer.
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