New CFPB Settlement Disclosure Form (HUD 1/1A) - Round 3
by Wyatt Bell
| 2012/01/26 |
Wyatt Bell's Blog ::
Here're the latest proposed Settlement Disclosures from CFPB (Consumer Financial Protection Bureau):
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We've been looking over the new Settlement Disclosure Form from CFPB and we've uncovered a couple of small items in the Butternut Bank proposed form.
The loan origination fee of $960.90 which is shown on Page 3 of 5, Settlement Fees, A. Origination Charges is off by $.10 cents. If you multiply the loan amount of $109,805.63 X .00875 you get $960.80 not $960.90.
The 2nd item that took awhile to find, and we think we have it, is on Page 1, Projected Payments. The Estimated Taxes, Insurance and Assessments show $551.25. The escrows on Page 3 of 5 totaled $422.94. We couldn't find any amount of $128.31 which is the difference.
However, by dividing the "Estimated Property Costs Not Escrowed" on Page 4 of 5 in the amount of $1,539.72 by 12 you get the quotient of $128.31.
I'm not sure this is clearer where one is instructed to jump to Page 3 and then to Page 4. In fact, it seems somewhat confusing!
Some of you may have read the post regarding the CFPB Proposed Settlement Form where the number $3,216.44 was shown on Page 5 of 6 under Closing Cost Summary:
CFPB Settlement Disclosure Forms
We couldn't derive that number from any figures on Page 3 of 6 which equates to the HUD Page 2 currently.
My colleague, Jimmy Lu, finally found the answer!
It turns out that the figure is derived from factoring the 211 County Tax Proration on Page 2 (equates to current Page 1 of GFE HUD) which is $1,038.84.
Therefore, Line 1400 = $8,410.28 - Total Settlement Fees at Closing = $4,155.00 - LIne 211 County Tax Proration = $1,038.84 == $3,216.44!!
($8,410.28 - 4,155.00 - 1,038.84 = $3,216.44)
Remember to factor the POC on the Credit Report and the Appraisal Fee.
This really will give Borrowers much greater clarity in the costs of their loan!! After we all stop laughing!!