They have good legal counsel. Any flat government fee - like the $5 conservation fee would be a line 1 item and lumped in to recording fees on the LE and it would be an other fee which is not itemized on Line 1 of the CD, just included in the totals.
Any fee that is based on the loan amount or sales price is a transfer tax on the LE. If there are multiple transfer taxes they are lumped on the LE and itemized on the CD.
Recording fee are subject to the 10% aggregate tolerance, however, transfer taxes are 0%.
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