[compliancegirl2012]

So if a third party provider prepared an evaluation for us and charged the Bank $75, could we charge the customer $200? If so, do we separate the fees?

[compliancegirl2012]

Also, we currently have a statement on our loan docs about future lien releases. We currently don’t collect them at closing but rather when the loan pays off. The problem is when we have a customer use our mobile app it doesn’t include late charges and lien release fees. Our Chief Financial Officer wants to know if we can charge our current loans a lien release fee by adding it to the loan balance.

[compliancegirl2012]

Thank you. I have another question then. Do we not have to include the same title insurance fees in our HOEPA calculation?

[compliancegirl2012]

We don’t retain the fee. The fee is sent to the title company. However, we do receive monetary compensation. Does the compensation make the fee subject to the 0% tolerance?

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