We are entering into an arrangement with a third party that will handle internet applications for us. They will obtain the application/lead from the internet aggregator, underwrite it, process it, and provide disclosures on our behalf. We will pay them a fee for each application. The amount of the fee will vary depending on various factors, such as loan amount, type of loan, etc., but there is a set schedule for how much we will pay them for each application. Out of this fee, the third party will pay for the costs of obtaining whatever type of appraisal is necessary, and getting title work, etc. Even if they end up needing to get a more sophisticated appraisal than anticipated, the fee we pay them will not change. The increased cost will simply leave them less profit on that loan. The borrower doesn't pay for any of this.
I was going to just include the amount of the fee to the third party in the Origination Charge, and then credit it back out in Block 2, so there is no cost to the borrower.
Is this acceptable? Or does the amount of each separate expenditure by the third party for appraisal, title search, etc. have to be separately disclosed in Blocks 3 and 4, and on the corresponding lines on the HUD?