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Can origination charges, including third party charges, be listed as a lump sum on a Loan Estimate and Closing Disclosure or should they be itemized separately?

Regulation Z (Truth in Lending Act) requires a Loan Estimate and Closing Disclosure that itemizes settlement services for closed-end, consumer purpose loans secured by real estate. May origination charges that include services provided by other entities, such as the investor’s tax transcript fees, be listed as a lump sum paid to the bank, or must they be itemized separately under the Origination Charges section?

If the fee is being paid to an entity or person other than the bank, the fees should be separately itemized and the entity or person receiving the fee identified on the Closing Disclosure as the recipient. See comment 3 to §1026.19(e)(3)(i). (November 2018)

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