Attorney Fees Location on the HUDA 1-A

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Question:

Should the attorney fees appear on the third page of the HUD 1-A (which is the comparison sheet with the original Good Faith issued)? It is to our knowledge that they should only appear here if the borrower selects their own attorney to prepare their title work (not an option at our bank). Therefore, we do not include this comparison. Just wanting to make sure that we understand this correctly.

Answer:

Any required service provider that is chosen by the bank the provider's fees are subject to the 10% tolerance so the fees would be on the comparison chart in the section for fees that cannot increase by more than 10%.

Depending on the services the attorney is providing their fees may need to be disclosed in Block 1 which has a 0% tolerance. You may want to review the 4/2/10 RESPA FAQs to be sure you are properly disclosing these fees.

First published on BankersOnline.com 9/19/11