We are implementing logic updates to the Origination Fee Percent and Discount Points Percent sections on the following documents:
- NY Interest Rate Lock Commitment (Cx3588)
- NY Prevailing Interest Rate Commitment (Cx3710
Under 3 NYCCR 38.4, lenders must disclose “the amount of fees and charges payable at time of commitment including points or other discounts, origination fees or add-ons.” The regulation does not specify which party pays these charges—only that they must be disclosed. To ensure compliance, we have adopted a conservative interpretation: Origination Fee and Discount Points will be disclosed regardless of who pays them.
Lines 3a and 3b on Cx3588 and Cx3710 are used to disclose these fees. We are updating the associated fields as follows:
- Origination Fee Amount
- Replace FI300 (Fee 801 Buyer Amount) with FI21855 (Total Expense for Line: 801).
- Origination Fee Percent
- For FHA loans: Replace FI42420 (Origination Fee Percentage of Base Loan Amount) with FI193900 (Total Origination Fee Percentage of Line 801 Expense ÷ Base Loan Amount).
- For non-FHA loans: Replace FI42420 with FI149079 (Total Origination Fee Percentage of Line 801 Expense ÷ Loan Amount).
- Discount Points Percent
- Replace FI20870 (Borrower-Paid Discount Points Percentage of Loan Amount) with FI52287 (Total Discount Fee Percentage of Loan Amount).
These changes are available for testing on Stage & Stage 2 servers and will take effect on November 27, 2025. If you have any questions or concerns about these changes, please contact Client Support at 1.800.497.3584.
COM-6694
DR-201488
The preceding is for informational purposes only and is not and may not be construed as legal advice. No third-party entity may rely upon anything contained herein when making legal and/or other determinations regarding its practices, and such third-party should consult with an attorney prior to embarking upon any specific course of action.