Notice: Function _load_textdomain_just_in_time was called incorrectly. Translation loading for the wp-migrate-db domain was triggered too early. This is usually an indicator for some code in the plugin or theme running too early. Translations should be loaded at the init action or later. Please see Debugging in WordPress for more information. (This message was added in version 6.7.0.) in /srv/app/gotoiba-dev/htdocs/web/wp-includes/functions.php on line 6121
Are lender paid closing costs excluded from the IHRHLA points and fees test? – IBA Compliance Connection

IBA Compliance Connection

Your go to source for compliance!

Are lender paid closing costs excluded from the IHRHLA points and fees test?

—

by

Provided that you are not retaining any portion of the closing costs, we believe that lender paid closings costs would be excluded from the “points and fees” calculation. The Illinois High Risk Home Loan Act (IHRHLA) exempts “bona fide third-party charges not retained by the mortgage originator, creditor, or an affiliate of the mortgage originator or creditor” from the points and fees calculation. 815 ILCS 137/10. As a result, any third party charges that your institution pays will not count towards the “points and fees” trigger for purposes of the Illinois law.