There is a fee to an attorney for drawing up the purchase agreement. We put it in the 1100 series (itemized in 1110) outside of the borrower's column. The title company insists it goes in the 1300 series, since the title company did not draw it up. Any opinions?

The purchase agreement wouldn't have anything to do with title services.

Well, I was leaning towards the following RESPA FAQ #11: If a borrower selects an attorney to represent the borrower's personal interests at settlement, and the service provided by that attorney is separate from the functions necessary to conduct the closing (and not required by the lender), provide title services or issue the lender's title insurance policy, this attorney's charge may be separately listed on a blank line in the 1100 series in the borrower's column along with the name of the attorney and the type of service provided. Accordingly, the amount of the attorney's fee should not be included in the charge listed on Line 1101.

LA LA, your section relates to an attorney representing the borrower at settlement. Your question was about drafting the purchase agreement. While I don't agreee with their reasoning, I do agree with the title company that this could go in the 1300 section because it has nothing to do with the closing. It's just a bill the borrower ran up and wants paid at the time of closing.

Okay,I should be happy it's not subject to any tolerance. Thank you!!!