You will need to prepare a HUD with the charges in the appropriate places and apply the appropriate tolerance which means you will most likely be refunding 100% of the origination charges and 90% of those costs subject to the 10% tolerance since a GFE was not provided.
BTW, when you said "all that fun stuff" I hope you didn't exclude flood because it would have applied even if the loan was secured by only the guaranty.
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The opinions expressed are mine and they are not to be taken as legal advice.