We are making separate construction-phase and permanent loans. Can we go ahead and charge the loan documentation fees for the second, permanent phase loan on the construction loan?

I suppose you could. I'm not sure that would be a wise thing to do however. Is sure messes up your GFEs for each phase and you will still have to show it as POC on the final HUD-1. Also, it sure makes FASB tracking a little difficult.

Thank you!

It also could be considered an UDAAP basically financially tying a customer to both loans with you instead of feeling free to shop.

Excellent point. I thin UDAAP is going to be the death of us all. It's hard to know what exactly will be considered "unfair."