What Do The HUD FAQs Really Tell Us?
The recently issued FAQs put out by the US Dept of HUD give us some confirmation of where we are moving down this RESPA Ready path.
In it, HUD answered over 50 questions from lenders, settlement agents and title agents. While the bulk of their questions were categorized as GFE related, there was information in these sections important to settlement and title providers. For example, the necessity under the new Rule to show 100% of title premiums on the GFE was restated. Another important clarification was the restrictions on issuance of a new GFE. The parameters and restrictions of revised GFE issuance was clearly stated - as were the time lines for GFE effectiveness. These are important things for loan and settlement service providers to know.
In the HUD-1 FAQs, the showing of fees in the 1100s sections was clarified. Also, the important new concept of "Title Services" being approached as a lump sum fee (similar to the lump sum origination charges in 801) was re-emphasized.
Of course, we still are in need of further clarification from some of the more in-depth questions that have been presented to The Dept of HUD. But these are a good first pass, and help us continue with our education, clarification and implementation process.
If, after reading HUD's FAQs (linked in the post immediately prior to this one) you have questions remaining ... we would love to hear them! We want to continue gathering your unresolved items and take them to HUD for further discussion and clarification.
If you don't have the time right now to fully read the FAQs (I really hope you do), schedule about 15 minutes during your week to read them and send us your follow up thoughts and questions.