Change in Origination Charges Before Closing

Compliance > Regulation X - RESPA > GFE and HUD-1
What are the consequences if the actual origination charges on the HUD-1 are different from the estimated charges that were disclosed in Block 1 on the GFE?

If the actual origination charges have decreased from what was disclosed on the GFE, there is no violation.  If they have increased, there will be a violation because the origination charges in Block 1 are fees that cannot increase under the tolerances.  As a result, the lender will be expected to waive or absorb the fee prior to closing, or refund the fee within 30 days after closing as a cure.  This can be found in several locations in HUD’s FAQs.

HUD's FAQs can be found at http://www.hud.gov/offices/hsg/rmra/res/respa_hm.cfm.

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