Re: Employee Loans



I think you are on the right track. If you know at the time of application that you are not going to charge a processing fee then I don’t think it should be included in the GFE. I looked through the Reg and some of the Q&A’s and didn’t find anything concrete on this.

You are correct on the disclosing of the waived title work.

The questions probably won’t stop unless the CFPB reworks RESPA. It’s a mess and there are way too may places to go to see if something is mentioned and you just hope HUD didn’t contradict their answers.