Forgive me if this has been asked already or if it is elementary, but I haven't found it in any searches and am having a time figuring it out...

On the new GFE, under "Summary of your loan", the question "Even if you make payments on time, can your monthly amount owed for principal, interest, and any mortgage insurance rise?", how would you disclose an interest only payment that is tied to a variable rate (WSJ Prime) that can change daily? I've figured out the maximum amount (use the ceiling rate), but how would I figure a dollar amount on the first increase? Use the same ceiling rate? And would I disclose it as able to change in 1 day? (This is for our construction loans where title is transferring to the first user.)

Thanks so much for your help....just got back into the compliance game this month.

Do we then have to provide a Recommended Provider list of title companies from which they can shop? We are choosing all other providers so we do not have a Provider list for any other services.

In a training today, heard from a big local title company owner that realtors are VERY concerned about making sure they get on the new provider lists that we have to give with the GFE. Okay - just to make sure I haven't missed a requirement - we are NOT supposed to put realtors on that recommended provider list, correct?!

Correct. Only service providers from Block 4-6 of the GFE.

bump

Has the settlement cost booklet been updated yet? Where would I find this on the HUD website? I've searched and searched and can't even find the old one!

During a 12/7 HUD webcast about RESPA, HUD stated that they thought that the new booklet might be released today (12/15). I've checked their website a few times today and don't see it.

The last page of the 11/19 RESPA FAQs states that the revised booklet would be posted on HUD's website and a notice would also be published in the Federal Register.

The current version (6/1997) of the booklet can be accessed from the following web page. http://www.hud.gov/offices/hsg/ramh/res/sfhrestc.cfm

For what it's worth:

My local FDIC field office (Kansas City region) stated, per a contact they have at HUD, that there should be some congruence between the GFE and the HUD-1 regarding property taxes. If we expect to collect a property tax payment on the HUD-1, it should be listed on the GFE. Conversely, if we don’t anticipate collecting the property taxes, they should not be listed on the GFE. (They should, however, be included as applicable in the escrow section.) So, consequently, going forward, an annual real estate tax amount will not be listed on the GFE. Shifting an anticipated closing date from one month to the next that would necessitate collecting the taxes, where previously they weren’t disclosed, would be a changed circumstance.

So, until we hear otherwise from something more official, it sounds like my offices at least needs to follow the above. (And ask me if I don't think this is going to somehow change in the next few weeks or month.)

What kind of "estimates" are we going to be seeing in block 11 - Homeowners Insurance?

I just spoke with my regulator and he indicated that there may be something coming down theline in March where basically if you require taxes to be paid, you will be required to escrow for the borrower.....

Looks like I get to do some hefty reading up on escrows since we have never done them in the past......

I've been searching too for the new (or old even) special information booklet on HUD's website (and I tried the link below too). I still don't see it. Is it in sections? I read where we might be able to order the booklets from the gov't for free too, but haven't found how/where.

Have searched this thread & can't find the answer - for our loans sold in the secondary market, if a borrower doesn't want to escrow, he has to pay an "escrow waiver fee" - guessing this would go in the Origination Charge?

Yep.

See my post above.

Here's a link to the PDF version of the booklet from 6/1997. http://www.hud.gov/offices/hsg/ramh/res/stcosts.pdf

I've been on vacation and am trying to get up to speed on this thread. JJ, since this was directed to me more-or-less, I'll risk it hasn't been answered and let you know...YES...unfortutely sales contract terms carry NO VALUE with HUD. Forget what you contract says the seller will do. OTI has to be quoted regardless of what is customary, what the contract says and who is going to pay it (for a purchase anyway)

For those that don't venture outside of this thread...I posted this in another thread, but I could use some help.
You may even get a free audit tool out of the deal

We have drafted a fee spreadsheet in excel, to detail different fee types and where they will fall on the GFE, the HUD and if the fee will impact the APR. But I could use a second set of eyes to review the thing.

Anyone interested?

Send me a PM if you would like it. By the way this is QCL.

We had the same delima. Our decision was to nix VRL on consumer construction that fell under RESPA. Which was the only category this would have applied to for us.

Thanks for the help. However, I don't know that management will nix VRL on these loans. If your bank had not nixed the VRL for these, how would you have handled the GFE issues in the summary section?

Thanks!

Swiggles, I didn't see this ever answered. So here goes:

You will have to disclose it (nothing new here) We didn't in the past, but with the new average charges, we feel we won't get away with that any longer. I think our average came out to a whopping $2.07 or something. Anyway, you can't list it as POC, you will have to disclose it in your orig charges on the GFE, then describe it on the HUD, and yes...it will be a credit if you don't intend them to pay it and since you can't show it POC, you won't be able to use a 1A.

Dan, I have to disagree. You can't show this as POC, you will have to show it and then issue a credit on page one.

Oh, I am already over that point and moving on, but thanks for answering

But new question/thought:

Many have mentioned on here doing a GFE "summary" if you will, to more accurately reflect the true closing costs (i.e. OTI, taxes, money to close, etc), separate from and in addition to the GFE.

How might this be percived by the examiners, and what can of worms might we be opening if we go down this route?

I'll ask them next month, if they ever get here. (We were postponed until January) We just developed this sort of thing and I think are planning on using it.

We discussed doing so today... more as of an LO tool, but for the customer's benefit as well.

Can someone tell me which line credit life should be disclosed on the new HUD form?