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Hey Robin I apologize but in looking at this again I totally misstated the problem and actually got it completely backward. I believe my Calculating Cash to close section is properly accounting for the general lender credit but it is not being accounted for at all in the Summaries of Transactions section. In this case my borrower is getting cash at settlement and the Cash to Close To Borrower is short by $200 in the Summaries Section. The Cash to Close amount in the Calculating section is correct. I’m trying to figure out where a general lender credit is accounted for in the Summaries section. When I read the regulatory text and the annotated forms it doesn’t seem to allow for it.
I’ll be there as well – really looking forward to it. I wanted to go last year but didn’t register in time so this will be my first time to attend this particular conference.
We have a somewhat similar setup but ours relates to a 3rd party that assists us with secondary market originations. Requests for short term portfolio loans go to our inhouse mortgage area, requests for longer term fixed rate loans would go to an originator who sits in one of our lobbies but is actually employed by the third party that does our processing and then ultimately buys our loans for resale in the secondary market. This person is technically an employee of the third party – we have an agreement for them to perform origination work for us and they provide an LO to work with our customers. In reading through the reg it states that “an employee of a creditor or loan originator that provides an application form from a different entity or directs a consumer to a loan origintor employed by a differnt entity is a loan originator under the rule.” So I think we’re going to have to make sure our teller staff refers everyone to our inhouse mortgage area and then they decide where the loan should be worked.
