- Business Rules
The Loan Estimate has a fixed number of fee lines and it was said that if you have more fees than lines, you will have to combine them. Is there any recommendation on what can/should be combined or is it all up to the Lender?An addendum to the Loan Estimate may not be used for items described under "Origination Charges" or "Services you cannot shop for". If the creditor is not able to itemize every service and every corresponding charge required in two sections, the remaining charges must be disclosed as an aggregate amount in the last line permitted under each section, as applicable, labeled "Additional Charges."
An addendum to the Loan Estimate may be used for items described in the "Services you can shop for". If the creditor is not able to itemize all of the charges required to be disclosed in the number of lines provided, the remaining charges must be disclosed as follows:
(A) Label the last line permitted with an appropriate reference to an addendum (e.g., See attached page for additional items you can shop for) and list the remaining items on the addendum in accordance with the requirements in paragraphs (f)(3) and (5) of 1026.37; or
(B) Disclose the remaining charges as an aggregate amount in the last line permitted under paragraph (f)(3)(ii), labeled "Additional Charges."
Citation(s): §1026.37(f)(6) and Commentary ¶37(f)(6)-2
CFPB announcement regarding the delay of TRID
The full statement from CFPB Director Richard Cordray can be viewed here