1. If lender gives employees a $400 lump sum credit towards closing costs not directly associated with any specific fee, would the $400 be deducted from the finance charge and total HOEPA points and fees in the APR and HOEPA covered loan calculations?

2. If the lender waives specific fees such as application fee $330; loan processing fee $380; and underwriting fee $500 totaling $1,210:
a. Is it permissable under RESPA for the fees to be listed as separate line items on the GFE and HUD1-A and the $1,210 employee credit shown seprately at the end?
b. If so, would the separate fees be required to be listed as "POC"?

Thanks