From 1026.4:
(c)(7) Real-estate related fees. The following fees (are excluded from the finance charge)in a transaction secured by real property or in a residential mortgage transaction, if the fees are bona fide and reasonable in amount:
(iii) Notary and credit-report fees.
You have the closing fees backwards:
(a)(2) Special rule; closing agent charges. Fees charged by a third party that conducts the loan closing (such as a settlement agent, attorney, or escrow or title company) are finance charges only if the creditor:
(i) Requires the particular services for which the consumer is charged
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