I've overthought this so much that I got myself all confused, so I just want to check and see if this appears correct.

The Bank generally pays the fees associated with HELOCs (i.e. credit report, flood, etc.). However, periodically, we'll have one where we have to order an appraisal or a title policy, and those costs have to be paid by the borrower. Would it be in line with Reg. Z ( Commentary 226.5b(d)(8)-2) to simply state in the application disclosure:

To open and maintain your Account, you must carry insurance on the property securing your Account. You must also pay certain fees to third parties. These fees generally total between $0.00 and $1,500. If you ask, we will give you an itemization of the fees that you will have to pay to third parties.

Then, the final disclosure they receive will detail what they actually had to pay.

Thank you! Just seems too simple.

I think that sounds right.

Ha! Ha! That's what I kept saying to myself but more with a question mark at the end. It just doesn't look right, does it, with there being such a big difference between $0 and $1500? But it's the truth.

I just saw a HELOC disclosure online with a range of $200 to $5,000.