We are moving forward with implementation of eRecording of real estate documents. There is a $5 service fee assessed for each document recorded, and we need to determine how to handle for our disclosures. We currently exclude the recording fees from the finance charge as they are security interest charges paid to public officials. Ideally, we would like to lump the eRecording fee with the recording fee paid to the county and exclude the entire amount from the finance charge. The entire amount will be paid to the company doing the eRecording and they will keep $5 and pay the county their fee. Has anyone dealt with this situation? Could we include this $5 in the recording fees disclosed on the GFE for the counties where it's available?

I would think it would be part of the Settlement Charges if the Title Company is keeping it.