For a Loan; the only upfront fee that can be charged is Credit
Normally there are two upfront fees for most residential real estate loans; the credit report and the appraisal.
Since the new law changes the only fee that can be charged up front now is the credit report. That report may cost between $16 and $25. We have this statement in our loan file set:
"Borrower and Broker acknowledge that Borrower may not be charged any fee other than a reasonable credit report fee (if applicable) prior to receiving initial disclosures from the Lender. these disclosures are in addition to those provided to Borrower by the Broker."
If the broker charges any fee - even in error- before the disclosures are sent from the Lender then the broker will have to pay for those fees; they cannot be charged to the client even if the loan funds and they are valid fees.
(408) 975-2400 X 110