Answer by Linda Westfall
You must show all costs incurred related to the loan. If a service is provided which has a related cost and you do not charge the customer, you must show the cost as POC on the Good Faith Estimate and the HUD1 Settlement Statement.
Answer by Lucy Griffin
The standard to use to determine whether a fee is disclosed is whether there is a fee and a service. If the lender pays the fee but does not pass it on to the borrower, the fee exists and must be included on the GFE and HUD1, shown as p.o.c.
There may be services that are standard or required in one market but not in another, such as filing requirements to perfect security. If the service and fee don't exist, the fact that they do and are disclosed in another market does not trigger a p.o.c. disclosure in the exempt market.
First published on BankersOnline.com 2/11/02