This paragraph on high cost mortgages prohibits the charging a consumer for "...any fee to modify, renew, extend or amend a high cost mortgage...." Without any clarification in the Commentary, it is unclear if "any fee" is restricted to a 'modification fee,' 'renewal fee,' 'extension fee,' or an 'amendment fee' or it also encompasses all other fees (e.g. appraisal fee, flood determination fee).

Looking at the section-by-section analysis in the final rule of 1-31-2013, they do use the phrase, "modification and deferral fees" in a couple of sentences, but then include the phrase, "...Congress intended the prohibition on 'loan modification and deferral fees' to be broad."

I know logic doesn't count, but it seems the prohibition is intended to prevent the contract holder from taking a fee and not to prevent the assessment of legitimate and actual costs paid to third parties. I'd appreciate a response from anyone having more experience or insight on this.