When we disclose the credit report fee on the GFE, does it matter what is used if we pay for the fee? Meaning; if our credit company charges us $15 for an individual and $25 for a joint, can I just use $20 across the board? Since we will show it as a credit on the HUD it wouldn't be as if we are overcharging the individual borrower since we pay for it.

You need to read the FAQ re: averaging costs and follow those guidelines no matter who pays the fee.

Agreed. I have to figure my averages every 6 months even when it changes by pennies, literally and update what we disclose on the GFE/HUD, even tho we pay it.

I read that, but I guess I couldn't get my brain to understand it. Why should it matter what fee we use if we pay for it. I know that is a question that has been asked for many years, but with all the recent changes in the compliance world, I have been questioning everything. Thank you both for your help.

When it comes to the GFE, it doesn't matter who is paying for what. The GFE is the worst case scenario of the cost of getting the loan. It has nothing to do with the particulars of any specific loan when it comes to banks or sellers or anyone else paying for or crediting the borrower for any particular cost. That's why you shouldn't look at the OTP before you do a GFE either.

Also, keep in mind that until the 2010 changes, we did not have 'average' charges. Those of us who didn't get individual CR costs got a bill sometime post consumption and really had no honest to goodness way of knowing the cost, so we didn't show it, even though technically, we should have been.

With the 2010 changes, the advent of the 'average charge' came into play which gave us a 'no way out' on that type of situation anymore.