NO COST HELOC – how should it be handled when all closing fees are paid by the lender? How should we disclose and how should we show it on the disbursement at closing.
We believe that we should not show the loan fee we usually charge because that fee would come to us anyway. Do we need to show fees subject to the finance charge if they are being paid by the lender? (for example… flood life of loan fee, loan fee to lender)
There are several other banks in our area offering this special right now. We want to make sure we are disclosing as we should.