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Under the TRID rule, are there exceptions to a zero tolerance fees?

Under the TRID rule, fees paid to the bank or an affiliate of the bank generally are subject to a zero tolerance, meaning that the fees on the Closing Disclosure cannot be higher than those on the Loan Estimate. Are there any exceptions?

Yes. Under Regulation Z §1026.19(e)(3)(i), fees paid to the bank or an affiliate of the bank generally cannot increase. However, fees that increase due to a valid changed circumstance or certain fees under §1026.19(e)(3)(iii), such as prepaid interest, property insurance premiums, amounts placed into an escrow account, and property taxes, may be paid to the bank or an affiliate of the bank and may increase as long as the fee is bona fide. See comment 4 to §1026.19(e)(3)(iii). (November 2017)

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