Profile for User: Jimmy.Graham

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  • in reply to: APR vs NON-APR fees on CD #10768
    Jimmy.Graham
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    Thank you for the response.

    I am so confused on this. We sell all of our loans in the secondary market. 4 of our major investors require that we break out the seller paid closing cost into the seller column and not show it as a lump sum. They actually have made us send out post consummation CD’s before they will buy the loan. Could this be coming from any other Reg or guidance? If it was just one investor, I wouldn’t think much about it but it is several ( Nationstar, Ditech, Texas Capital Bank & Freedom Mortgage Group ). In your opinion, Are we out of compliance by showing the seller paid closing cost broken out in the seller column ( Currently, we assign non APR fees to that column to cover the credit )

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