CFPB TRID Sec. 13.2 - Are there any limits on fees that may be charged prior to disclosure or application?

Compliance > Regulation Z - TILA / TRID Specific > General Info
Q:  Are there any limits on fees that may be charged prior to disclosure or application?
 
A:  Yes. A creditor or other person may not impose any fee on a consumer in connection with the consumer’s application for a mortgage transaction until the consumer has received the Loan Estimate and has indicated intent to proceed with the transaction. (§ 1026.19(e)(2)(i)(A))
 
This restriction includes limits on imposing:
  • Application fees;
  • Appraisal fees;
  • Underwriting fees; and
  • Other fees imposed on the consumer.
 
The only exception to this exclusion is for a bona fide and reasonable fee for obtaining a consumer’s credit report. (§ 1026.19)(e)(2)(i)(B); Comments 19(e)(2)(i)(A)-1 through -5 and Comment 19(e)(2)(i)(B)-1)
 
 
This information can be found in the CFPB's TILA-RESPA Integrated Disclosure rule compliance guide - http://www.consumerfinance.gov/regulatory-implementation/tila-respa/
 

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