What makes the situation worse than before is that the Bureau has chosen to include loan officer compensation and
GSE loan level price adjustments (LLPAs) in the calculations as well.
NAR urged the CFPB to fix the cap on fees and points with regard to counting of originator compensation,
GSE loan level price adjustments, and title insurance charges.
Not exact matches
The
GSE commenter noted that other fees disclosed on the Closing Disclosure, such as mortgage insurance and
loan level pricing adjustments, are tied to the
loan - to - value ratio which is, in turn, determined by the value used for underwriting.