In order to be more competitive our sales department would like to move the cost of the credit report and Online VOE verifications fees from Sect. B on the LE and increase our Administration Fee in Section A slightly. My question is since these are 3rd party services the borrower cannot shop for but is required to process the loan can we remove those fees from B and just increase our administration fee?

Our sales manager tried to make the same argument and told me our competitors were doing it and he had seen it. I asked him to send me examples. He sent me 8 LE's, seven of them did it correctly (by not lumping).

Allowable fees are a State law issue.

How is increasing an Administrative Fee going to make your bank more competitive?
If I were an applicant, seeing an Administration Fee of $250 plus a cbr and VOE fee (explainable fees) looks better than just a $500 administrative fee.
jmho

Other than the state law piece, yes, you could do that. If you want to be the one that pays the Credit Report company, you can charge an additional admin fee to cover that. Seems like you would run the risk though of losing out on a good amount of money in instances where you pulled the credit report and then had to deny the borrower or withdraw the borrower before collecting your comprehensive Admin fee.