Concerning itemizing the fees the customer will have to pay to third parties. At my institution the bank covers the credit report fee. Since we pay the fee, does it need to be included on this disclosure.

The commentary to 1026.40(d)(8) where it talks about including rebates of third party fees is what is making me wonder.

Also, I have the same question for the disclosures required under 1026.6. Would the credit report fee be listed if the bank was paying the fee?

HELOCs are not like TRID. Only fees paid by the consumer need to be disclosed.

40(d)(8) deals with rebates. If you charge the fee at account opening and they are eligible for a rebate of the fees some time down the road, those have to be disclosed.