I think you are.
That's why I have long advocated NOT giving lender credits on the GFE.
Do a cover letter that states either:
*At time of closing, you will receive a bank credit of x% of loan amount.
*At time of closing, bank will give a credit to cover actual cost of (appraisal, cbr, etc)., not to exceed $x.
That way the bank won't burn itself giving out free money.