Truth in Lending Changes Take Effect July 30, 2009

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1 July 21, 2009 RMC Truth in Lending Changes Take Effect July 30, 2009 On July 30, 2008 Congress enacted the Housing and Economic Recovery Act of 2008, which included amendments to TILA, known as the Mortgage Disclosure Improvement Act (MDIA). The Implementation of MDIA will take effect for all applications taken on and after July 30, The MDIA requires creditors to give good faith estimates of mortgage loan costs, known as early disclosures, within three business days after receiving a consumer s application for mortgage loan and before any fees are collected from the consumer, other than a reasonable fee for obtaining the consumer s credit history. While 3 day doc s have been part of our disclosure requirement for some time the MDIA broadens our responsibility to disclose/re-disclose changes in the APR prior to closing. Summarized below are the rules for all loan applications received beginning July 30, 2009: 1. Initial Fees Lenders may only collect a fee for the reasonable cost of a credit report prior to the issuance of the initial disclosures. Disclosures must be given before the consumer pays any fee, other than a bona fide and reasonable fee for obtaining the consumer's credit history Initial Disclosure Statement Lenders must continue to issue disclosures 3 business days from application, however, the issuance of the initial TIL Statement now extends to "any extension of credit secured by the dwelling of a consumer" which includes refinance transactions, second homes and home equity loans. Seven Business Days Prior to Consummation Lenders must allow applicants to have a 7 business day waiting period after mailing or delivering the TIL prior to closing of the loan. This timing is not based on receipt date (or assumed receipt date) by the consumer- the timing begins with the mailing or delivery by the lender. Revised APR Three Business Day Notice If the APR is out of tolerance (+/-.125% from previously disclosed APR), lenders must re-disclosure three business days prior to consummation. The loan may not close until 3 business days after the borrower has received the re-disclosure. Notice of "No Requirements to Complete" The MDIA requires that the early disclosures contain a clear and conspicuous notice containing the following statement: "You are not required to complete this agreement merely because you have received these disclosures or signed a loan application." Disclosures produced by Mortgage Builder have been re-designed to include this statement.

2 6. Business Day The definition of business day for both the 3 and 7-day waiting periods is all calendar days except Sundays and holidays Received Date If disclosures are sent via US Mail they are considered received 3 business days from the day they are mailed. Waivers Borrowers may waive both the seven-day and three-day waiting period to meet a bona fide personal financial emergency. However, if the TIL Statement is out of tolerance, the waiver is no longer effective. After redisclosure, borrowers must submit a signed statement describing the emergency. Denied or withdrawn applications Lenders may determine within the threebusiness-day period that the application will not or cannot be approved on the terms requested. If the consumer withdraws the application within the threebusiness-day period, the creditor need not make the disclosures under this ruling. 10. Written application RESPA defines a written application as the submission of a borrower's financial information in anticipation of a credit decision relating to a federally related mortgage loan. An application is considered received when it reaches the creditor by mail, hand delivery, or through an intermediary agent or broker. Any application that includes the following six items triggers the disclosure requirement: Borrowers name Borrowers social security number Property address Loan amount Borrowers estimate of value Borrowers monthly income See Attached Exhibit A Working together to ensure timely closings Exhibit B Sample origination to close calendar Exhibit C Potential impacts to the APR Exhibit D Truth in lending FAQ/Finance Charge Matrix

3 Working together to ensure timely closings everyone plays a key role Borrower REALTOR /Builder Loan Officer Title Company/ Settlement Agent Obtain a credit-checked preapproval before you start to shop for a home. Review the timeline and potential impacts with your loan officer so you can keep your REALTOR or Builder informed. It is wise to plan for at least a 30-day close. In the initial disclosure packet you receive, the impacts of the new regulations and investor requirements are outlined. Make sure to pose any questions to your loan officer. Know that these new regulations and investor requirements are in place to ensure you have time to consider your loan choice and feel confident to move forward. Understand that the interest rate on your loan impacts the APR. This means that until you lock in your rate, an exact APR cannot be determined. Minimally plan on locking at least 7 business days prior to the date you wish to close. Understand that a change in mortgage product could impact your APR and therefore your estimated closing date. Understand that changes in fees by third parties such as your settlement agent could also impact your closing date. Set realistic expectations upfront and throughout the transaction with the listing agent, the seller and the borrower in regards to potential closing dates. It is wise to plan for at least a 30-day close. Discuss these new provisions with your settlement agents immediately to avoid unnecessary delays down the road. It is critical that any third party fees that impact the APR are accurate because any change of fees that increase/decrease the APR more than.125% will require a re-disclosure of the TIL allowing 6 business days before transaction can close. This allows 3 business days for mailing and provides the borrower with the time required to determine if they are comfortable with their loan choice. Provide the settlement agent information to the loan officer as early in the process as possible. Make sure the borrowers understand that their interest rate impacts their APR and that until that rate is locked (which is at their discretion), the initial TIL will not be accurate, so a subsequent TIL disclosure will likely be needed. Help borrowers understand timeliness and anything that can impact their closing date including changes to the APR. It is wise to encourage borrowers. REALTORS, and Builders to plan for at least a 30-day close. Take applications and help borrowers understand their product options. Issue borrowers their initial disclosures. Collect fees and request the appraisal. (Note: fees cannot be collected nor the appraisal requested until 4 business days after the borrower has been issued his or her initial TIL. The only exception is the credit report fee which can be collected at application). Ensure the loan is locked at least 7 business days prior to the desired close date. Understand that any change to fees that impacts the APR could lead to a required re-disclosure of the TIL. If the APR increases/decreases more than.125% then the lender must re-disclose the TIL before the transaction can close. This allows 3 business days for mailing and provides the borrowers with the time required to determine if they are comfortable with their loan choice Make sure any third party fees that impact the APR are accurate understanding any change to fees that impact the APR could lead to a required redisclosure of the TIL (if they collectively increase/ decrease the APR more than.125%). The redisclosure requires the borrower be given an additional 3 business days review period prior to closing after receipt. Work proactively on providing a preliminary HUD with accurate fees to lenders enabling them to issue the TIL 6 business days prior to the scheduled closing date. This allows 3 business days for mailing and provides the borrowers with the time required to determine if they are comfortable with their loan choice. The best way to expedite the close is to lock in the rate and fees as soon as possible. EXHIBIT A: 7/2009

4 Sample Origination to Close Calendar August 2009 Sunday Monday Tuesday Wednesday Thursday Friday Saturday Originator registers and locks loan (35day lock) 9 10 Initial Disclosures Day5 4 Originator mails/delivers Initial Disclosures to borrower 5 Initial Disclosures Day1 12 Initial Disclosures Initial Disclosures Day6 Day APR is Finalized Revised TIL is mailed to client TIL Review Day TIL Mail Day 1 Borrower can Sign/ Close ALL final Conditions to RMC 26 TIL Mail Day 2 T & L changes take effect 6 Initial Disclosures Day2 Earliest Day to close per initial disclosure review period Borrower finalizes purchase Contract 7 Initial Disclosures Day Conditional Approval from RMC RMC issues CTC LO Submits Closing Request w/ final fees/figures 27 TIL Mail Day 3 28 TIL Review Day 1 Earliest Day to collect upfront fees/ order appraisal 8 Initial Disclosures Day TIL Review Day 2 EXHIBIT B: 7/2009

5 Potential impacts to the APR Unlocked rate Change in loan amount Product Changes Change in closing date Changes to fees, inclusive of settlement fees Important Dates to Remember Wait requirement period Required wait time (in business days) 1. Initial disclosure review 7 days after mailing 2. Upfront fee collection (other than credit report) 4 days after mailing 3. Borrower appraisal review 3 days to mail plus 3 days to review prior to closing 4. APR change of.125 plus TIL reissue 3 days prior to mail plus 3 days to review prior to closing EXHIBIT C: 7/2009

6 Truth In Lending (TIL) FAQ Annual Percentage Rate Finance Charge Amount Financed Total of Payments The cost of your credit at a yearly rate. The dollar amount the credit will cost you. The amount of credit provided to you or on your behalf The amount you will have paid after you have made all payments as scheduled. A B C D What is a Truth-In-Lending Disclosure (TIL) and why do I receive it? This is a Disclosure designed to give you information about the costs of your loan so that you may compare these costs with those of other loan programs or lenders. It is usually prepared in combination with the Good Faith Estimate. The Federal government requires TIL to be provided to the borrower within 3 business days of loan application. What is the ANNUAL PERCENTAGE RATE? (Box A above) The Annual Percentage Rate (APR) is the cost of your credit expressed as an annual rate. Because you may be paying loan discount points and other prepaid finance charges (PFC) at closing, the APR disclosed is often higher than the interest rate on your loan. This APR can be compared to the APR on other loan programs to give you a consistent means of comparing rates and programs. Note: Be careful when comparing different lenders using the APR. Some lenders do not include all items as prepaid finance charges that should be, which can result in a lower APR than it actually is. Why is the ANNUAL PERCENTAGE RATE different from the interest rate for which I applied? The APR is computed from the Amount Financed and based on what your proposed payments will be on the actual loan amount credited to you at settlement. In a $87,200 loan with $2, Prepaid Finance Charges (PFC), a 30 year term and a fixed interest rate of 6.375%, the payments would be $ (principal & interest). Since the APR is based on the Amount Financed ($84,258.47), while the payment is based on the actual loan amount given ($87,200), the APR (6.706%) is higher than the interest rate EXHIBIT D: 7/2009

7 What is the FINANCE CHARGE? (Box B above) The Finance Charge is the cost of credit expressed in dollars. It is the total amount of interest calculated at the interest rate over the life of the loan, plus Prepaid Finance Charges (PFC) and the total amount of any required mortgage insurance charged over the life of the loan. What is the AMOUNT FINANCED? (Box C above) The Amount Financed is the loan amount applied for, minus the Prepaid Finance Charges. Prepaid Financed Charges (PFC) include items paid at or before settlement, such as loan origination, commitment or discount fees ( points ), adjusted interest, and initial mortgage insurance premium. The Amount Financed is lower than the amount you applied for because it represents a NET figure. If you applied for a $87,200 loan and the Prepaid Finance Charges total $2,941.53, the Amount Financed would be $84, Note: Prepaid Finance Charges are marked on the Good Faith Estimate with a PFC to the right of the amount. Does this mean I will get a smaller loan than I applied for? No. If your loan is approved in the amount requested, you will receive credit toward your home purchase or refinance for the full amount for which you applied. In the example above, you would therefore receive a $87,200, not a $84, loan. What is the TOTAL OF PAYMENTS? (Box D above) This figure represents the total amount you will have paid if you make the minimum required payments for the entire term of the loan. This includes principal, interest and mortgage insurance premiums, but does not include payments for real estate taxes or property insurance premiums. My Disclosure says that if I pay the loan off early, I will not be entitled to a refund of part of the finance What does this mean? This means that you will be charged interest for the period of time in which you used the money loaned to you. Your prepaid finance charges are generally not refundable nor is any interest which has already been paid. Usually, this will only be checked Yes if you are applying for an FHA loan since FHA loans require an Upfront Mortgage Insurance Premium that may be partially refundable if you refinance your loan within a certain number of years. EXHIBIT D: 7/2009

8 FEES LISTED ON HUD 1 Lender/ Broker/ Affiliate Finance Charge Matrix JULY 2009 FINANCE CHARGE Paid To: Title/ Closing Only fees that are bona fide and reasonable in amount can be excluded from the finance charges 1 2nd/Second Mortgage Fee YES YES YES YES 2 Abandonment (of Homestead) NO NO NO NO 3 Abstract or Title Search NO NO NO NO Title fee. Accomodation Fee YES YES YES YES 4 5 Additional Checks YES YES YES YES Additional Work Charge 2nd 6 Processing YES YES YES YES Same as Overnight Fees, Express Mail Fees, Admin/Courier/Fax/Copy Fee YES YES YES YES 7 Delivery Fee, etc 8 Administration Fee YES YES YES YES Not a finance charge if for Affidavit recording Affidavits YES YES NO YES 9 (paid to Gov't entity) or for document preparation. 10 Agency Fee (FHA) YES YES YES YES 11 ALTA x.x NO NO NO NO Title fee. 12 Amortization Schedule Fee YES YES YES YES 13 Annual Assessments NO NO NO NO Taxes. 14 Annual Fee YES YES YES YES For HELOCs- Not a finance charge unless based on usage. For CE- Always a finance 15 Application Fee YES YES YES YES 16 Appraisal Desk Review YES YES YES NO Not a finance charge if paid to an Appraiser. 17 Appraisal Fee NO NO NO NO 18 Appraisal Field Review YES YES YES NO Not a finance charge if paid to an Appraiser. 19 Appraisal Review YES YES YES NO Not a finance charge if paid to an Appraiser. 20 Archiving Fee YES YES YES YES 21 Assessment Search Fee NO NO NO NO Title fee. 22 Assignment Recording fees YES YES YES YES 23 Assumption Fee YES YES YES YES 24 Attorney's Fees YES YES YES YES Same as Settlement or Escrow or Closing. 25 Automated Underwriting YES YES YES YES 26 Automated Valuation Model (AVM) YES YES YES YES Not a finance charge if < $ Bankruptcy Service Fee NO NO NO NO 28 Broker Admin Fee YES YES YES YES 29 Broker Appraisal (BPO) YES YES YES YES 30 Broker Fee YES YES YES YES 31 Broker Processing Fee YES YES YES YES 32 Building Permit NO NO NO NO 33 Buydown Paid by Borrower YES YES YES YES 34 Cancel Existing Loan Fee YES YES YES YES 35 Capital Contribution YES YES YES NO Not a finance charge if paid to HOA. 36 CEMA YES YES YES YES Not a finance charge if paid to a Governement Certificate of Release YES YES NO YES 37 entity for recording. 38 Certified Copies to Registry NO NO NO NO Title fee. 39 CES/Closed End Second YES YES YES YES 40 Check Processing Fee YES YES YES YES 41 City Property Taxes NO NO NO NO 42 City/County Tax/ Stamps NO NO NO NO Not a finance charge if paid by someone other CLO YES YES YES YES 43 than the borrower. 44 Closing Fee YES YES YES YES Same as Settlement or Escrow or Attorney. 45 Closing Letter YES YES YES YES Not a finance charge in AR, LA, MO, NJ, NC, OH Closing Protection Letter YES YES YES YES 46 & PA if imposed by title for issuing a CPL. 47 Closing Protection Premium NO NO NO NO Title fee. Not a finance charge in AR, LA, MO, NJ, NC, OH Closing Service Letter YES YES YES YES 48 & PA if imposed by title for issuing a CPL. 49 Combo Fee YES YES YES YES 50 Commitment Fee YES YES YES YES 51 Compliance Cert/Reg Copy YES YES YES YES 52 CON/MOD YES YES YES NO Not a finance charge if paid to HOA. 53 Concurrent Junior Mortgage Escrow Fee YES YES YES YES 54 Condo PUD Approval Fee YES YES YES YES 55 Condo Questionnaire fee YES YES YES YES Not a finance charge if required by the state to be Conservation Fee YES YES YES YES 56 charged to the borrower. 57 Construction Admin Fee YES YES YES YES 58 Contingency Fee NO NO NO NO 59 Copy or Fax Fee YES YES YES YES 60 Cost to Broker YES YES YES YES 61 County Property Taxes NO NO NO NO 62 County Surcharge Fee NO NO NO NO 63 County Taxes NO NO NO NO 64 Courier Fee YES YES YES YES Same as Overnight Fees, Express Mail Fees, Gov't Other COMMENTS Last Revised 3/18/ of 6

9 FEES LISTED ON HUD 1 Lender/ Broker/ Affiliate Finance Charge Matrix JULY 2009 FINANCE CHARGE Paid To: Title/ Closing Gov't Other COMMENTS Only fees that are bona fide and reasonable in amount can be excluded from the finance charges 65 Credit Report NO NO NO NO Deed of Trust (DOT) Release YES YES NO YES Deed Prep Fee NO NO NO NO 68 Demand Fee YES YES YES YES Not a finance charge if for payoff of old loan 69 Desktop Underwriter Fee YES YES YES YES 70 Digital Docs YES YES YES YES 71 Disbursement Fee YES YES YES YES Discharge of Mortgage YES YES NO YES Discount Fee YES YES YES YES 74 Doc Imaging YES YES YES YES 75 Doc Service Fee YES YES YES YES 76 Docufile YES YES YES YES 77 Document Certification YES YES YES YES Not a finance charge if for Doc Preparation, and if Document Fee YES YES YES YES 78 bona fide and reasonable in amount. 79 Document Fee ( or Printing) YES YES YES YES 80 Document Handling Fee YES YES YES YES 81 Document Maintenance Fee YES YES YES YES Not a finance charge if for Doc Preparation, and if Document Preparation NO NO NO NO 82 bona fide and reasonable in amount. 83 Document Processing YES YES YES YES 84 Document Retrieval YES YES YES YES 85 Document Review YES YES YES YES 86 Document Signing Fee YES YES YES YES 87 DocuServe YES YES YES YES 88 Draw Fee YES YES YES YES HELOC fee to draw. Not a finance charge if for Doc Preparation, and if Draw Fee (Document Preperation) NO NO NO NO 89 bona fide and reasonable in amount. 90 DU/LP Fee YES YES YES YES 91 Duplicate Tax Bill YES YES YES YES 92 Early Issue Fee NO NO NO NO Insurance Premium 93 E-doc Fee YES YES YES YES 94 Electronic Doc Delivery Fee YES YES YES YES 95 Electronic Recording Fee YES YES YES YES 96 Endorsements NO NO NO NO Title fee. 97 Environmental Protection Lien NO NO NO NO Title fee. 98 Equity Set Up Fee YES YES YES YES 99 Escrow Accounting Fee YES YES YES YES 100 Escrow Fee YES YES YES YES Same as Settlement or Closing or Attorney. 101 Escrow Hold Back Admin. Fee YES YES YES YES 102 Escrow Sales Tax YES YES YES YES 103 Escrow Waiver Fee YES YES YES YES 104 Estoppel Fee NO NO NO NO Title fee. 105 Express Mail Fee YES YES YES YES Or overnight delivery, shipping and handling. 106 Expressline Processing Fee YES YES YES YES 107 Extra Check Charge YES YES YES YES 108 Fax Fee YES YES YES YES 109 FHA 203K Termite Fee YES YES YES YES Not a finance charge if done prior to closing 110 FHA 203K Title Update Fee YES YES YES YES Not a finance charge if done prior to closing 111 FHA MIP YES YES YES YES 112 FHA MIP Impounds YES YES YES YES 113 FHLMC REO Delivery Fee YES YES YES YES 114 File Maintenance YES YES YES YES 115 Filing Fee YES YES YES YES 116 Final Title Update NO NO NO NO Title fee. 117 Finance Charges YES YES YES YES Flood Fee (if Cert is NOT Life of Loan) Not a finance charge if for upfront flood determination only. 118 NO NO NO NO Finance charge IF part of fee is for life of loan Flood Fee (if Cert is Life of Loan) YES YES YES YES 119 monitoring. Not a finance charge if for insurance or upfront Flood Insurance Services YES YES YES YES 120 flood determination. Not a finance charge if for insurance or flood Flood Report Fee YES YES YES YES 121 determination. 122 Flood/Hazard Insurance Premiums NO NO NO NO 123 Florida Form 9 NO NO NO NO Title fee. 124 Funding Fee YES YES YES YES GA Residential Mortgage Fee YES YES NO YES 125 entity and if fee = $ Gap Risk Fee YES YES YES YES 127 Government Service Fee YES YES YES YES H.O.M.E to Commonwealth 128 Land Title YES YES YES YES Last Revised 3/18/ of 6

10 FEES LISTED ON HUD 1 Lender/ Broker/ Affiliate Finance Charge Matrix JULY 2009 FINANCE CHARGE Paid To: Title/ Closing Gov't Other COMMENTS Only fees that are bona fide and reasonable in amount can be excluded from the finance charges 129 Hand Recording YES YES NO YES 130 Handling Fee YES YES YES YES 131 Hazard Insurance NO NO NO NO 132 Hazard Insurance Premium NO NO NO NO 133 HELOC Fee YES YES YES YES 134 HOA Dues NO NO NO NO 135 Imaging Fee YES YES YES YES Inspection Fee YES YES YES YES Not a finance charge if for an inspection of the property, and the service is performed before 136 closing. 137 Intangible Tax NO NO NO NO 138 Interest YES YES YES YES 139 Investor Fee YES YES YES YES 140 ITI Agent Registration Fee YES YES YES YES 141 Judgment Fee NO NO NO NO Title fee. 142 Judgment Search NO NO NO NO Title fee. 143 Jumbo Pool Fee YES YES YES YES 144 Junior Loan Policy NO NO NO NO Title fee. 145 L109 PIRT NO NO NO NO Title fee. 146 LARA Analysis YES YES YES YES 147 LARA Escalation YES YES YES YES 148 Legal & Vesting NO NO NO NO Title fee. 149 Lender Direct Fee YES YES YES YES 150 Lender Fee YES YES YES YES 151 Lender's Coverage NO NO NO NO Title fee. 152 Lenders Inspection Fee YES YES YES YES Not a finance charge if for an inspection of the property, and the service is performed before closing. 153 Lien Finance Report NO NO NO NO Title fee. 154 Lien Protection Insurance NO NO NO NO Title fee. 155 Lien Search NO NO NO NO Title fee. 156 Limited Realty Report NO NO NO NO Title fee. 157 Line Entry Fee YES YES YES YES 158 Loan Discount YES YES YES YES 159 Loan Fee YES YES YES YES 160 Loan Origination Fee YES YES YES YES 161 Loan Package Fee YES YES YES YES 162 Loan Package Preparation Fee YES YES YES YES 163 Loan Review Fee YES YES YES YES 164 Loan Tie-In Fee YES YES YES YES 165 Lock in Fee YES YES YES YES 166 Master Servicer Administration Fee YES YES YES YES 167 MCC Application Fee YES YES YES YES 168 MCC Fee to Agency YES YES YES YES 169 MCC Fee to Lender YES YES YES YES 170 Mechanical Lien NO NO NO NO Title fee. 171 MERS Fee YES YES YES YES Same as Overnight Fees, Express Mail Fees, Messenger Fee YES YES YES YES 172 Delivery Fee, etc 173 Miscellaneous Lender/Broker Fees YES YES YES YES Mortgage Certification Fee YES YES NO YES Mortgage Fee YES YES YES YES 176 Mortgage Insurance Application fee YES YES YES YES 177 Mortgage Insurance Impounds YES YES YES YES 178 Mortgage Insurance Premium YES YES YES YES 179 Mortgage Insurance Service YES YES YES YES 180 Mortgage Registration Tax NO NO NO NO entity for recording. If anything is charged above Mortgage Tax to Title YES YES NO YES Government If the tax is imposed on the MRB Compliance Fee YES YES YES YES 183 MRB Funding Fee YES YES YES YES 184 Municipal Lien Certificate NO NO NO NO Title fee. 185 Name Search NO NO NO NO Title fee. 186 Nav Serv NO NO NO NO Title fee. 187 NCHFA Processing Fee YES YES YES YES NOC Recording YES YES YES YES Notary (Mobile) YES YES YES YES Only if Mobile Notary. 190 Notary / Signing YES YES YES YES The notary fee is not a finance charge, but the signing fee is. If lumped together, then the total is a finance Last Revised 3/18/ of 6

11 FEES LISTED ON HUD 1 Lender/ Broker/ Affiliate Finance Charge Matrix JULY 2009 FINANCE CHARGE Paid To: Title/ Closing Gov't Other COMMENTS Only fees that are bona fide and reasonable in amount can be excluded from the finance charges The notary fee is not a finance charge, but the Notary and Signing YES YES YES YES signing fee is. If lumped together, then the total is 191 a finance Not a finance charge if paid to the notary; if only Notary Fees YES YES YES NO 192 for the notorial action and is < $ Notice of Seizure Fee YES YES YES YES 194 Notice of Settlement YES YES YES YES 195 NY Consolidation & Modification YES YES YES YES 196 O & E Report NO NO NO NO Title fee. 197 Obtain & File Release Document YES YES YES YES 198 Obtain & Record Municipal Lien YES YES YES YES 199 Order Demand Statement YES YES YES YES 200 Origination Fee YES YES YES YES 201 OTC 442 Reinspection YES YES YES YES 202 OTC Additional Draw Inspections YES YES YES YES Not a finance charge if the title endorsement is OTC Foundation Title Endorsement YES YES YES YES 203 obtained prior to closing. Not a finance charge if the survey is done prior to OTC Survey YES YES YES YES 204 closing. The notary fee is not a finance charge, but the Outside Loan Signing/Notary Fee YES YES YES YES signing fee is. If lumped together, then the total is 205 a finance 206 Overnight Fee YES YES YES YES 207 Owner's Coverage NO NO NO NO Title fee. 208 Patriot Act Service Fee YES YES YES YES If the fee is for the service to payoff credit cards or Payoff Credit Card YES YES YES YES 209 other debt it is a finance 210 Payoff Service Fee YES YES YES YES 211 PCOR Fee YES YES YES YES 212 Per Diem/Interest YES YES YES YES 213 Pest Inspection NO NO NO NO 214 Piggyback Second YES YES YES YES 215 Plan Review Fee YES YES YES YES 216 Points YES YES YES YES 217 Post Closing Fee YES YES YES YES 218 Private Mortgage Insurance YES YES YES YES 219 Private Mtg Insurance Impounds YES YES YES YES 220 Private Mtg Insurance Premium YES YES YES YES Not a finance charge if paid to Nehemiah as a Processing Fee YES YES YES YES cost for getting the grant, this is not a cost in 221 connection with the loan 222 Processing Fee to Bond Authority YES YES YES YES 223 Property Valuation Fee YES YES YES YES 224 Quality Assurance YES YES YES YES 225 Quit Claim Deed NO NO NO NO 226 Rapid Lien Fee YES YES YES YES Rec/Filing Fee YES YES NO YES Recertification Fee NO NO NO NO 442-Certification for completion. 229 Recertification Fee to Title NO NO NO NO Title fee. Not a finance charge if paid to recorder to record Reconveyance Fee YES YES YES YES satisfaction on the old loan. This is a cost of the 230 old loan, not a finance charge on the new loan. Tracking of this recordation process is a service, Recon Tracking Fee YES YES YES YES 231 and so is a finance Record Mortgage YES YES NO YES entity for recording. If anything is charged above 232 Record Request for Notice YES YES NO YES entity for recording. If anything is charged above 233 Record Solo & Separate YES YES NO YES entity for recording. If anything is charged above 234 Record Warranty Deed YES YES NO YES entity for recording. If anything is charged above 235 Recording Escrow Fee YES YES NO YES entity for recording. If anything is charged above 236 Recording Fees YES YES NO YES entity for recording. If anything is charged above 237 Recording Handling Fee YES YES NO YES entity for recording. If anything is charged above 238 Recording Satisfaction Fee YES YES NO YES entity for recording. If anything is charged above 239 Last Revised 3/18/ of 6

12 FEES LISTED ON HUD 1 Lender/ Broker/ Affiliate Finance Charge Matrix JULY 2009 FINANCE CHARGE Paid To: Title/ Closing Gov't Other COMMENTS Only fees that are bona fide and reasonable in amount can be excluded from the finance charges Recording Service Fee YES YES NO YES Re-Draw Fee (Document Preparation) YES YES YES YES 241 Reimbursement YES YES YES YES 242 Release Fee YES YES YES YES 243 Release Recordation YES YES NO YES 244 Remote Document Fee YES YES YES YES 245 Remote Fee YES YES YES YES Rental Housing Support Act YES YES NO YES Report Fee YES YES YES YES Request for Notice if Required 248 by Lender YES YES YES YES Residential Housing 249 Support Program YES YES NO YES 250 Residential Mortgage Fee YES YES NO YES 251 Return Package Fee YES YES YES YES 252 RHS Guarantee Fee YES YES YES YES RHSP YES YES NO YES Rush Recording Fee YES YES YES YES Rush Recording Fee Paid 255 to a Gov. Agency YES YES YES YES 256 Sales Tax NO NO NO NO 257 Sales Tax Paid to a Gov Agency NO NO NO NO entity for recording. If anything is charged above Government If the tax is imposed on the Government If the tax is imposed on the Satisfaction Fee YES YES YES YES Not a finance charge if the fee is to satisfy the old loan being paid off. Then it is a cost of the old 258 loan, not a finance charge on the new loan. 259 Scan Fee YES YES YES YES 260 Search & Exam NO NO NO NO Title Search 261 Service Fee YES YES YES YES 262 Service Release YES YES YES YES 263 Settlement or Closing YES YES YES YES 264 Settlement/Escrow Agnt Misc. fees YES YES YES YES Shipping/Handling Admin 265 Service Fee YES YES YES YES 266 Shortfall Fee YES YES YES YES 267 Sign Up Fee YES YES YES YES The notary fee is not a FC, but the signing fee is. Signature Fee YES YES YES YES 268 If lumped together, then the total is a FC. 269 Signing Fee YES YES YES YES 270 Simultaneous Issue YES YES YES YES 271 Simultaneous Second YES YES YES YES 272 Stand Alone 2nd YES YES YES YES 273 State Documentary Transfer Tax NO NO NO NO 274 State Tax Stamps on Mortgage NO NO NO NO 275 State Tax/Stamps NO NO NO NO 276 Statement Fee YES YES YES YES 277 Statutory Policy Fee YES YES YES YES 278 Storage Fee YES YES YES YES 279 Streamline Valuation Fee YES YES YES YES 280 Sub-Escrow or Sub Title Fee YES YES YES YES 281 Subordination Fee YES YES YES YES 282 Supplemental Origination Fee YES YES YES YES 283 Survey NO NO NO NO Tax Certificate Fee YES YES NO YES Government If the tax is imposed on the 284 Tax Payment Fee YES YES NO YES Government If the tax is imposed on the 285 Last Revised 3/18/ of 6

13 FEES LISTED ON HUD 1 Lender/ Broker/ Affiliate Finance Charge Matrix JULY 2009 FINANCE CHARGE Paid To: Title/ Closing Gov't Other COMMENTS Only fees that are bona fide and reasonable in amount can be excluded from the finance charges Tax Registration Fee YES YES NO YES Government If the tax is imposed on the 286 Tax Related Fee YES YES NO YES Government If the tax is imposed on the Tax Report Fee YES YES YES YES Same as a Tax Service Fee 289 Tax Report Processing Fee YES YES NO YES Government If the tax is imposed on the Tax Search Fee YES YES YES YES Not a finance charge if tax search was part of the title work to verify the taxes and whether paid Tax Service or Tax Contract Fee YES YES YES YES 292 Tennessee Service Charge YES YES YES YES 293 Third Party Processing Fee YES YES YES YES 294 Tie in Fee YES YES YES YES 295 Title Cancellation Fee YES YES YES YES Not a finance charge if for title exam, abstract of title, title insurance, property survey and similar purposes and is bona fide and reasonable in amount 296 Title Examination NO NO NO NO Not a finance charge if for title exam, abstract of title, title insurance, property survey and similar purposes and is bona fide and reasonable in amount 297 Title Insurance NO NO NO NO Not a finance charge if for title exam, abstract of title, title insurance, property survey and similar purposes and is bona fide and reasonable in amount Title Insurance Binder NO NO NO NO Not a finance charge if for title exam, abstract of title, title insurance, property survey and similar purposes and is bona fide and reasonable in amount Title Service Charges YES YES YES YES Not a finance charge in Missouri 300 Tracking YES YES YES YES 301 Transfer Fee YES YES YES YES 302 Typing Fee YES YES YES YES 303 Underwriting Fee YES YES YES YES 304 Update Fee YES YES YES YES 305 Up-Front MIP YES YES YES YES 306 VA Funding Fee YES YES YES YES 307 VHDA Bond Loan Fee YES YES YES YES 308 VOD - Verification of Deposit YES YES YES YES 309 VOE/ Verify of Employment Fee YES YES YES YES 310 Walk Thru Recording YES YES YES YES 311 Warehouse Fee YES YES YES YES 312 Wire Fee YES YES YES YES 313 Wire Handling Fee YES YES YES YES 314 Work Share Fee YES YES YES YES 315 WV State Loan Fee YES YES YES YES 316 YSP YES YES YES YES Not a finance charge if paid by someone other than the borrower. Last Revised 3/18/ of 6