Might be time to switch compliance consultants.
Tell them to read the commentary:
5b(d)(7) Fees Imposed by Creditor
3. Fees not required to be disclosed. Fees that are not imposed to open, use, or maintain a plan, such as fees for researching an account, photocopying, paying late, stopping payment, having a check returned, exceeding the credit limit, or closing out an account do not have to be disclosed under this section.
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