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Per TILA-RESPA Integrated Disclosure rules, fees that are not disclosed separately, must be aggregated first with actual values, totaled and then rounded. The Expere Tools have been modified to support this scenario.
Prior to this enhancement, fees that are not disclosed separately would round each fee first and then be summed together to obtain the total which results in a compliance error where the totals can be off by $1 or more depending on the number of fees and amount of the fees.
On the Loan Estimate, for Loan Costs and Other Costs Sections that have fees that exceed the maximum number to be disclosed are aggregated together and disclosed as "Additional Charges" in Subsections A, B, F, G and H, and C (if addendum is not used). For these fees that are aggregated together and disclosed as "Additional Charges", the rounding method has now changed to use the "Total First, then Round" method since these fees are not separately itemized and disclosed (previously, the "Round First, then Total" method was used). As a result of this change to the "Additional Charges" rounding method, the section totals and subtotal sections have been updated to reflect this change.
This applies to both TXN and MISMO Expere Knowledge Base Content versions.
Code of Federal Regulations Information: 12 CFR 1026.37(f)(6). 12 CFR 1026.37(o)(4)(i)
The Requirements Editor 3 Tool has been enhanced to add new elements and attributes to support the new rounding method. The Expere Engine Stylesheet has been modified to add logic to utilize new elements/attributes and implement new rounding method to for calculating totals for fees that are not disclosed separately.
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