New here, don't want to make waves, but, does this sound kosher to you?

We consistently (every time) overdislose, intentionally, by assuming worst-case-scenario services that borrowers seldom even need, plus worst-imaginable fees on everything, so that our GFEs are never quoting a figure that is higher (or even close to) what the finalized charges will be. We explain, day after day, borrower after borrower, that they can "not worry about" the figures on the GFE, because "they are inflated" and "we HAVE to quote you higher than what you will actually be charged."

i'd rather consistently disclose too high and come in low than the other way around. But I'd also consider making changes so that estimates of charges were much more in line with actual and based on fees customer will be having, not worst case scenario for ones they won't have a need for. Sounds like a "we've always done it this way" issue.

One major regional bank was doing something similar and were told by the regulators that they need to concentrate on getting the GFE accurate, and not inflating to reduce reimbursement risk. Also mentioned that it appeared a systemic inaccuracy which will be reviewed very close the next exam. Bank corrected.

Another thing to consider. The GFE is suppose to be a shopping tool. If everything is inflated, they may decide to go somewhere else where it appears to be cheaper. Isn't accuracy going to get tighter under the new disclosures?