we have a low HELOC and the title exam would put the heloc into HCM status - puts it over $1000 if points and fees.
but we are allowed to exclude if:
1. The charge is reasonable;
2. The creditor receives no direct or indirect compensation in connection with the charge; and
3. The charge is not paid to an affiliate of the creditor.

So here, assuming the charge is reasonable we should be able to exclude the title exam and thus not trigger HCM status. No question here other than my thoughts are reasonable?
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My views, not my employer's views.