NEW RESPA requires that when initial GFE is mailed, no fees can be collected other than Cr rep, for 3 calendar days after mailing. What about no fee loans? I ask because, if we have a lst lien transaction with a quick turnaround, would we have to wait the 3 days if there is no cost to the borrower at closing? All fees are p.o.c. by lender. Does no fees include p.o.c. by lender fees?