Customer has a HELOC with our bank. The customer is refinancing his current first mortgage (from a different lender) to lower the rate with us. In order to secure a first lien, we would have to “subordinate” our position for the HELOC and take first position with the new loan. The Consumer Loan Department charges a subordination fee. Would this fee be disclosed in the 800 series since it will be a bank fee from a different department?

I would agree with the 800 series since it is a bank charge and being paid to the bank. It also will be a PPFC.

Okay - other way around. Other bank is charging a subordination fee in order for our bank to be in first lien position. From other posts, I see that the fee will be a PPFC and disclosed in Block 3 of the GFE. So on the HUD Statement, does it go in the 800 series, payable to the other bank, and inside the column marked "POC" if paid before closing?

I know this is the Lending forum and this is a RESPA question, just piggy-backing on the original post.

Thanks!

Sounds correct to me.