Clearly, the question of what numbers to use on a GFE applies today as well as under the 1/1/10 rules. But I imagine Pink's question was focused on the rules after 1/1/10, since then if the fees go up after initial disclosure, a new GFE must be issued. (And, of course, there must be a legitimate reason for the increase in fees, i.e., "changed circumstances.")
At our bank, we pay almost all of the third-party fees for the borrower. Most of the time, the borrower's only cost is the loan/origination fee. (Only exceptions would be for the occasional situation where we require title insurance or if the collateral is in a state with doc stamps and/or intangible taxes--the borrower pays these fees.)
We start out ordering a low-level evaluation for the property, and work our way up from there as needed. There are about 5 different levels (and charges, of course) of appraisal and we don't necessarily know until we get an appraisal back whether or not we need to advance to the next level. (For example, we might go from an AVM to a Desktop to a walk-through, depending on what value comes back on each and how that relates to the requested loan amount.) It's all irrelevant to the borrower because we're paying the costs. But it appears under the new rules that we would need to provide a new GFE each time we order another appraisal because the fees increased, even though it doesn't impact the borrower's bottom line. So I'm wondering if we can just use perhaps a middle level appraisal charge on each GFE so we don't have to keep issuing a new GFE everytime we order a more advanced appraisal. Again, none of this has any impact on the borrower.