We currently charge a Future Release Fee at closing. This fee is put into a G/L account and when a loan is paid off, the funds for releasing the lien is debited from that account. I know that in the recent past this practice has been scrutinized (prior to TRID concerns). I know that the tolerance would be Zero with TRID. As of yet, we have had no negative comments about the practice from examiners. I would appreciate any comments about the ability to continue this practice after October 3rd.

Thank You!!!

We also do that, but are having issues. While this fee is included in the total in the LE and CD; it is not listed separately in the descriptions. Our LOS company has been advised, but don't think it will be corrected prior to 10/3.

I too would be interested in hearing how this should be handled on the Closing Disclosure. We also charge this fee - our LOS combines this fee with the Warranty Deed recording fee, then lists the Mortgage Recording Fee separately. The total of the fees is the Release + Deed + Mortgage.

Skittles and AC, in what section do you think this fee should be disclosed on the LE and CD?? My thoughts were, since we are not paying it to the county until the end of the loan term, it is actually paid to us and should be in Section A-Origination charges. But I am not sure??

After some research, I'm in your camp KMG365. We take the fee to income, we don't put it into an account that is reconciled. My attempts getting rid of the release fee didn't work with management. So, I plan on putting in the Origination Charges - and it is a finance charge.

Any other thoughts on where this fee belongs? We are starting to set up a product that has this fee and am not certain where it should go. Right now, it is set up under H. Other Costs.

AF-23 touched on an issue with this type of fee that must be addressed.
There are numerous discussion threads on this topic

I googled 'collecting release fee in advance bankersonline' and got this from rlcarey which summarizes it nicely.

Thank you Truffle.