I have an examiner telling me that Box 5 on the GFE cannot be blank it must say N/A. Can someone show me where this is stated?

Appendix C.

Block 5, “ Owner's title insurance. ”—In this block, for all purchase transactions the loan originator must provide an estimate of the charge for the owner's title insurance and related endorsements, regardless of whether the providers are selected or paid for by the borrower, seller, or loan originator. For non-purchase transactions, the loan originator may enter “NA” or “Not Applicable” in this Block. The charge shown in this block is subject to an overall 10 percent tolerance as described above.

Gotta love how the word 'may' is interpreted.

That is what I wondering. Does may now mean must? Does your software place N/A in the box?

Our software puts 'not applicable' in the box. If you're software doesn't do that, call the company and ask them why not. Last time we had an issue, the software company came up with ammunition to use with the examiners.

Alternately, as long as the examiners agree 'may' does not equal 'must' so you don't get cited, you could try capitulating to putting it in going forward.

It's not telling you "may" as in you have a choice not to put anything at all in the box. It's saying you have the choice to either put NA or Not Applicable in the box. Therefore you may/can put either one in the box but you have to put one or the other.

Not arguing with you, Dan. Just sayin' that's not how I or the original poster read it. I'm betting we're not the only ones either. Plain English would have left May out of it and read something more like: 'for non-purchase loans enter NA or not applicable....'

It could be interpreted either way. To be specific, they needed to say "must enter either NA or Not applicable".

FWIW, our software defaults to NA...we have to know to input an amount on Purchase transactions.

also FWIW, I think it's a silly requirement. There's either a number there or there isn't. Most in-house lenders never require it. How is blank any different from NA when it's all said and one...neither one add anything to the bottom line!