We disclosed a credit report fee of $20 on our LE. We subsequently learned that the fee has increased to $30 and we're ready to issue our Closing Disclosure.

There are 2 ways to disclose: one to show $20 in the Borrower Paid column and $10 in the Paid by Others column and that's it.

Seems our software has some issues with this and wants to show the $10 in Section J with the language: Lender Credits, includes $10 credit for increase in Closing Costs above legal limit. In this case, we'd show $30 in the Borrower Paid column with the $10 in Section J. Would the above legal limit language be required in this case? Our software wants to include it regardless. If not required, is it okay to have it appear?

Thank you.

Not sure why that would be? If you estimated $20 on the LE and the borrower is paying $20 - why is there a cure regardless of whether some of the fee is paid by others?

Sounds like you have a software issue and should talk to your support rep.

We only use the "legal limit" clause when we give a general credit for a tolerance issue. However for zero tolerance fees we always give a specific credit in the paid by other column for the fee that is out of tolerance.

Thank you - yes software issues. Seems they can't do the specific lender credit and this is their workaround.

Either way is fine. I just think most FIs don't want to show their fees exceeded legal limits and would rather handle the tolerance cure as a lender paid item.

Thank you.

Tell your software provider that the regulation provides two ways to resolve such issues, and that you want the software to provide both options. This two-option solution has been in the TRID regulation since the beginning. Your software provide needs to update its software -- or you should consider looking for an alternative.

If you have a user group, that group can put more pressure on the provider.

Good point - thank you!