Whether you advance the closing fees to the borrower's checking account or to your GL account the first advance is still financing start up fees and the initial periodic statement would have to make the required disclosure in 1026.7.
8. Start-up fees. Points, loan fees, and similar finance charges relating to the opening of the account that are paid prior to the issuance of the first periodic statement need not be disclosed on the periodic statement. If, however, these charges are financed as part of the plan, including charges that are paid out of the first advance, the charges must be disclosed as part of the finance charge on the first periodic statement. However, they need not be factored into the annual percentage rate. (See § 1026.14(c)(3).)
The opinions expressed are mine and they are not to be taken as legal advice.