NFLP RESPA Reform Blog

Calyx is currently structured so that fees shown in Section 3 that are "required services that we select" do not show up on the Service Provider List and the fee amount input rolls into the origination charges in Section 1.  This is not incorrect as required by RESPA Reform.  However, many want to show these as separate fees so payment can be made through the title agent directly to the contract processor at closing.  So you will still show as a Section 3 fee and it does not matter whether you show the processing fee on Line 810 for Processing or add as an additional fee in Section 800 on the IFW, the fee amount will be added to Section 1 origination charges.  If the fee is for a contract processor, the section regarding who the fee is paid to should show "Other" and not "Lender".  The same question has been raised about appraisals and collecting a fee upfront. 

 

If the item will be paid upfront, you collect a fee from the borrower and explain that this fee will be credited back at closing against the origination charges in Section 1.  If the item will be paid direct to someone at closing, explain to the borrower that the fee will be paid at closing for contract processing and credited back against origination charges in Section 1.  In neither case will the fee be shown on the Service Provider List nor does it need to be.