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Ability to Repay points and fees- Affiliated Business

Home Forums Dodd-Frank Act Ability to Repay points and fees- Affiliated Business

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  • #2621
    compliancegirl
    Participant

    If we have a title company as an affiliate (own 16%), would fees paid to the title company be included in the points and fees under the ability to repay?

    #3040
    jholzknecht
    Keymaster

    Generally, fees paid to a title company that is an affiliate will be included in the total of points and fees. There are several elements to the definition of an “affiliate,” but generally a company must owns 25% or more of a company for it to be an affiliate.

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