HUD Revises their RESPA FAQ Document; I Always Feel Like...
Posted by Anthony Demangone
September. Can someone tell me where the Summer went? Oh, I almost forgot. Reg Z stole it. But I digress.
On Friday, HUD issued a revised version of its RESPA FAQ document. Unfortunately, the document doesn't highlight the new or changed material. You can access the FAQ here.
For those tracking or responsible for implementing the changes found in the RESPA amendments, this is a must read. For example, these questions and answers can clear up areas that were very murky. For example, just when can you charge fees on a RESPA-governed loan, other than for the cost of obtaining a credit report? Voila!
Q: At what point can a loan originator charge a loan applicant fees for services other than the cost of obtaining a credit report?
A: After a loan applicant both receives a GFE and indicates an intention to proceed with the loan covered by the GFE, the loan originator may collect fees beyond the cost of a credit report for origination-related services. (Emphasis added.)
Now, this is interesting, because this requirement is nowhere to be found within the new RESPA regulation. But it does make sense from a consumer's point of view. So, when tackling a RESPA issue - be sure to check this FAQ document to see if it addresses your issue.
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A few weeks ago, I took part in a very funny e-mail discussion about Reg Z. The three compliance officers and I found that Reg Z was very much like the GEICO stack of money from their ever-present commercials. Regulation Z, like the GEICO stack of money, is always there. Lurking. Although, with some important differences.
First, rather than the happy googly eyes, I envision the Reg Z mini mascot to have a angry look or menacing stare. Second, the music would be much different. I envision hearing Darth Vader's theme music. If anyone has other suggestions, please share them in the comments section.