I need an opinion. We are contemplating charging future fees for things such as lien release, UCC continuation, and release of mortgages. The bank will not make any income on this. Do we need to disclose this? If so, where? If we disclose on our documents, we realize if there is an increase in fees, we will just have to absorb the additional costs.

Any suggestions?

If you are collecting them when originating the loan, you need to reflect on your disbursement authorization and TIL. If you are going to collect latter at time of payoff, simply show on your disbursement authorization future estimated fees to release lien. If you use laser pro it has a box to check and it makes it very easy.