I am still having trouble reconciling the RESPA FAQ to the July RESPA Roundup – this is true even after reading much discussion in these threads.

We are still handling OTI the same way we did it when the new RESPA rules went into effect in January because I was waiting for more clarification – or something – from HUD. This is what we do (which I believe follows instructions in the FAQ):
A) Always put OTI on the GFE for home purchase loans.
B) Put OTI in the borrower’s column on the HUD-1.
C) Show a credit for OTI in the 200 Series and a charge to the seller in the 500 series.
D) The comparison chart contains amounts in the GFE and HUD column for OTI.

Our Software vendor seems to be making changes to comply with the RESPA Roundup which says:
“If the consumer did not purchase a service that was listed on the GFE (usually owner’s title) there should be nothing entered in that line on Page 2 of the HUD-1 and the estimate of the charge should not appear on the comparison chart on Page 3 of the HUD-1.”

1) Is the “consumer” in this case our borrower or does it mean any consumer (seller) associated with the loan?
2) Is HUD saying to show the OTI in the Seller’s column of the HUD-1?
3) Does HUD still expect us to put the OTI on the GFE for a purchase?

We usually pay for the flood determination rather than passing the fee to the consumer. We handle it basically the same way we do the OTI.
•Does this also fall off of the comparison chart now?

What I want to ask is Why? Why? Why? But I know it’s pointless so I won’t.

Taken from the Banker Online Blog.