Solving Common Violations

Reg X: RESPA

3500.7(a): Timely delivery of GFE

• Include prototype GFEs in application packets.
• Check procedures to be sure loan intake officers provide timely (immediate) information about new applications.

3500.7(c): Content of GFE

• Review GFEs for completeness. Compare a sample of GFEs to the final HUD-1s to identify any information that should appear on GFEs.
• Determine whether fees disclosed are within range of the final numbers.
• Provide lenders with sample completed GFEs.
• Develop and use a GFE checklist.

3500.7(e): Required service provider

• Compile a list of required services and required providers for staff who prepare GFEs.
• Include the names, addresses and telephone numbers of required service providers!!
• Remind staff (in training, meetings, or memos) about the required service provider disclosures. Include this on your GFE checklist, above.
• Assign the monitoring responsibility of checking the fees of required service providers.

3500.8(b): Accuracy of fees on HUD-1

• Train on completing HUD-1s. Provide an example of completed HUD-1s and a check list.
• Give staff a list of top problems in completing HUD-1s.
• Establish procedures for disclosing fees paid outside of closing ("p.o.c.").
• Give staff a list of fees that are likely to occur outside of closing. Include these on the checklist.

3500.21 (b): Transfer of servicing

• Customers must sign this notice - even if it only happens at closing. Put it on the loan closing checklist.
• Audit your transfer of servicing notices annually to be sure they are current.

Previous highlighted violations:
Reg C: Home Mortgage Disclosure Act
Reg B: Equal Credit Opportunity
Reg E: Electronic Funds Transfers
Reg H

Copyright © 2001 Compliance Action. Originally appeared in Compliance Action, Vol. 6, No. 6, 6/01