If we charge a courier fee for lets say FedEX, that is included in our origination charge, it is a FC but can it be excluded from P&Fs since it is paid to a third party, or does it have to be inlcuded since it is lumped in with our origination charge?

Thanks

bump

I am not a Board Guru, but here is my opinion. This is where RESPA and ATR/QM can easily be confusing.

Yes, the Fedex charge is a PPFC and part of Origination Charges for the GFE. If your origination charge is a flat fee (all inclusive, regardless of how much Fed ex costs), then my opinion is that it is included in the points and fees test.

If you have separate billing for your Fedex, and charge the borrower the exact amount (no up charge), thus your origination charge frequently varies, then the Fedex charge can be excluded and the lower origination charge (less Fedex) would be in P&F.

Just one person's perspective.

Thanks