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#2289952 - 10/20/23 03:06 PM Admin Fee on LE/CD
Everest Offline
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Joined: Jan 2012
Posts: 307
We have an investor that we sell our mortgage loans to that wants to start charging a $300 Admin Fee. This needs to be added to our LE but I am wondering if it should go in Section A (Origination Charges) or Section B (Services Borrower Did Not Shop For).
The investor will short our funding of the loan for this Admin fee when it is sold to them. On the CD would we reflect that the Fee is payable to the investor or do we put our bank name?

TIA for all help.

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Lending Compliance
#2289954 - 10/20/23 03:43 PM Re: Admin Fee on LE/CD Everest
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 85,273
Galveston, TX
If you are selling to that specific investor, why don't you ask them which placement is acceptable. Personally, they are neither the creditor or loan originator for a Section A charge.
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#2289964 - 10/20/23 05:40 PM Re: Admin Fee on LE/CD Everest
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,862
Bloomington, IN
The investor will short our funding of the loan for this Admin fee when it is sold to them.

That sounds like that is an administration fee being charged to the bank for the settlement of the loan into the secondary market and is not a fee associated with the borrower obtaining the loan. It's a fee for the bank selling the loan to this particular investor.

If the bank is passing that charge to the borrower then IMO that is part of the bank's origination fees for processing the loan and would be disclosed as such.
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The opinions expressed are mine and they are not to be taken as legal advice.

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