We are considering making a recommendation to management that we stop using the "average" method of credit report fee calculation.
If we decide to do this - is it as simple as getting the powers that be to sign off, changing our procedures, and doing it?

OR - do we have to do something to validate the average fee that we've used over the most recent term - and if that validation showed that our average fee was too high, would we have to go with an average again for the next 6 months at a reduce rate to make up for it as per the regs before we could abandon the averaging method entirely?

Did something change that now allows you to know up front what the actual charge will be?

Yes.

I think that if that's the case, I would document the reasons, stop calculating the 6-mos average, and begin charging the actual charge.

Whether you do that now, or at the beginning of your new 6-mos period probably doesn't matter too much.