I have an FHA loan with The Money Store. I got a call today from the closer saying she is cutting my fees because they are including the upfront MIP as a fee that falls under Sec. 32. Is this right? I thought Sec. 32 was regarding broker and lender fees, not the financed MIP!. Can I get specific info on what fees fall under Sec. 32. I read your article, but it is still unclear.
Section 32, high cost mortgage loan disclosures, requires that you include not only broker compensation, but other finance charge components as well. The cost paid for lender/guarantee insurance is in that category. I can see why they want it included.
There is no list of specific fees, as what bank A charges and what bank B charges may have the same name, but could differ in purpose and payee, so there are broad descriptions on some lists but these are not definitive. What you would need to do is open Regulation Z and read that. In particular look at §226.32(b). We won't copy and paste that here, because you have references back to other sections of the regulation and that would extend, and potentially confuse the average consumer reader.
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