Yes.

I think this would qualify as a changed circumstance, if you didn't know about it at the time you prepared the GFE.

You never list "POC" on the new GFE If you require it, it is listed on the GFE and HUD-1/1A. It would be listed as POC on the Settlement Statement.

I agree the HOA cover more than just the insurance, but HOA dues are sometimes due at closing and are shown on the HUD. Where are you going to show them on the good faith if not under #11?

I apologize. I'm still confused, David. If I NEVER have an amount, how can I put it on the GFE?

Proof of insurance will be on my confirmation of commitment letter. The HOA will provide us with a copy of the insurance with our unit # on it. In this instance, do I just not include insurance on the GFE?

We never had an amount either for the insurance, but we did how on HUD that we had insurance for a 1 year term POC by the association. I don't know if we are going to be able to do this anymore.

I have HOA dues, but they don't pay my insurance.

Insurance is unlimited tolerance, so I'm not sure what the big deal is.

True, but there are also prorations for any number of things-oil in the tank, etc, which have no bearing on the loan. We don't currently put any amounts due for HOA fees on the GFE-we include the monthly amount in the PITI section, but not a prorated amount.

And David makes a great point-put them on line 11 where there is no cap on the tolerance amount.

If HOA dues, [censored] dues, Condo Assc. dues, or property taxes are on the HUD and split between the buyer and seller, is it your understanding that these charges do not need to go on the Good Faith Estimate?

If they need to go on the Good Faith, where would you but them?

On the good faith, the only reference to taxes is the amount to be escrowed, if any. Otherwise, the other fees you noted are not lender required fees, so they would not be disclosed on the GFE, IMHO

Any fee the borrower might pay for AND that you require must be listed on the GFE.

Taxes are definitely not listed on the GFE. I don't think HOA and Condo Assoc. dues go on the GFE - as I stated in an earlier post. If this pays for the hazard insurance, then I guess it will need to be listed. Most likely Block 11.
(I'm not sure what you typed that was censored)

I have a question regarding lists of providers. Do we have to give the client a list for title companies. There are only about three or four in our area. We are required to give them a list for services they can shop for correct? Our bank doesn't require any services that they can shop for example pest. We don't require pest inspections or survey's. Sometime, the borrower may want to have this done but is done at their option, not required. This would not have to be disclosed on the GFE correct?

Our state does title opinions, so they do neeed an attorney to read the title opinion. My understanding is that fee will go in box 4 for title services and we must give a list of attorney's.

The more I read, the more confused I become

If you list a fee on the GFE and allow the borrower to shop for the provider, you MUST provide a list of providers.

Lock Extension Fee - always in Block 1?

If a lock agreement expires, we charge a lock extension fee. If it was the bank's fault, the bank eats the fee, but if it's the customer's fault, we require the customer to pay it.

1) Is this a changed circumstance? I'm thinking yes because you would not know at the time you initially issued the GFE that the process would extend beyond the lock period, but I'm probably wrong.

2) Does this fee go in block 1? I believe it does as it doesn't seem appropriate to put it any where else. Then, if the bank is the one paying the fee, I guess you would simply credit it back on the front page of the HUD?

Thanks in advance for setting me straight.

Notice David's "and" above. You could elect to not allow them to shop, if you can get away with that.

FWIW, i agree with you.

I would go along with all said regarding the lock fee as well.

I'm trying to figure out how to complete the new GFE for our "no cost" home equity loans. We pay all of the closing costs on these, which includes the flood certification, credit report, attorney fee, recording fee and appraisal fee. The flood certification, credit report, attorney fee and appraisal fee are paid to a third party. We don't charge any origination fees and no points.

Are we to list the amounts of the settlement fees that we are paying in boxes 3-11 and put a negative amount somewhere in box 1 or 2, or are we supposed to give them a GFE that has zeros instead of what we will be paying for the customer?

Any advice is greatly appreciated!

We don't do home equity loans, but we do a fair amount of no cost loans-lender paid. We will be showing the standard fees in the appropriate boxes, but the amount of credit will be shown in Box 2. The result will be a negative number since the credit will be covering fees over and above what is in box 1.

From the Q&A:

Q: How does a loan originator show a ―no cost‖ loan on the GFE?
A: Where a ―no cost‖ loan encompasses the loan origination charge and some or all third party fees, a credit should be listed in Block 2 of the GFE to offset all fees encompassed in the ―no cost‖ loan resulting in a negative number in Block A to cover the intended third party fees, listed in Blocks 3 thru 11 as appropriate.

So, you will list your credit in Block 2 for items you are paying in 3-11. Caveat...if you over estimate this credit...you will still be bound to it. The Q&A goes into more detail on that situation somewhere...maybe in the HUD section. It also could be in this thread as a direct question to HUD with an answer from a poster.

Looking for advice...
On a Second REM where hazard insurance and taxes are all ready current- do we have to have them POC on the GFE and/or HUD???

You no longer have to disclose taxes. YOu will show the estimate for the insurance, just like always. You will not be held to any tolerance on that figure, however.
If the customer has already paid it, it should be pretty understandable that they won't really have that cost at closing, just like before.

There is no provision to use POC on the new GFE. It can only be used on the new HUD-1 and HUD-1A.

See this prior discussion regarding homeowner's insurance.

Thanks reads, I totally ignored the POC part of that question! It probably needed to be laid out in the answer! LOL!

[So, you will list your credit in Block 2 for items you are paying in 3-11. Caveat...if you over estimate this credit...you will still be bound to it. The Q&A goes into more detail on that situation somewhere...maybe in the HUD section. It also could be in this thread as a direct question to HUD with an answer from a poster.]


It's question 4 under GFE - Blk 2, at the bottom of pg 23 of HUD Q & A.

Has anyone come up with an "Intent" letter they might be willing to share? I am having a hard time coming up with something that gets the point across without getting too wordy.