late fees and penalties. The problem is that all of these types of fees have to be justifiable, and completely spelled out. Most loans have RESPA and TILA violations. Up to 70% of the loans currently in effect have RESPA and TILA violations. This means that the Real Estate Standards and Procedures Act and/or the Truth in Lending Act was violated when your loan was originated. This gives you recourse up to and including the hypothetical invalidation of the loan itself! Talk about leverage …