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TIL Disclosure Statement

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  • #2530
    lsmith5
    Member

    What types of fees should be listed on this disclosure under”Other charges paid in cash”?

    Appraisal fee, recording fee, document preparation fee, flood certification fee, credit report fee, homeowners insurance?

    I’ve read and re-read Reg Z and can’t find an answer to this question.

    Thanks.

    #2958
    JGo9
    Participant

    lsmith5,

    I don’t think that you will find anywhere in the reg that talks about what you must list in that section. I believe you are talking about the itemization of fees, which doesn’t always have to be done on a TIL.

    12 CFR 1026.18 (c)

    (c) Itemization of amount financed. (1) A separate written itemization of the amount financed, including: 40

    40 Good faith estimates of settlement costs provided for transactions subject to the Real Estate Settlement Procedures Act (12 U.S.C. 2601 et seq.) may be substituted for the disclosures required by paragraph (c) of this section.

    (i) The amount of any proceeds distributed directly to the consumer.

    (ii) The amount credited to the consumer’s account with the creditor.

    (iii) Any amounts paid to other persons by the creditor on the consumer’s behalf. The creditor shall identify those persons.41

    41 The following payees may be described using generic or other general terms and need not be further identified: public officials or government agencies, credit reporting agencies, appraisers, and insurance companies.

    (iv) The prepaid finance charge.

    From your question, it sounds like that particular heading comes from the format that a particular loan processing vendor has created, thus you will not find that specific question addressed in the regulation.

    The following is a list of sections that I normally see with that vendor:
    – Amount paid on my account:
    – Other Charges Financed:
    – Total Financed Prepaid Finance Charges:
    – Note Principal:
    – Prepaid Finance Charges:
    – Amount Financed:
    – Other Charges Paid in Cash:

    It is my opinion that typically you would list any other charges that don’t have a home in one of the other sections. Typically in my neck of the woods I see Homeowners Insurance listed here, and not much else.

    I hope this helps. Look on the bright side, at least it is not RESPA!

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