We have a relationship with a Broker who is requesting to be reimbursed for the Credit Report Fee as well as the VOE fee they are incurring in the initial application process. I am trying to figure out how to show who this is made payable to on the CD. We will be reimbursing the broker but she is not technically the third party that provided the required service. How are others showing this?

You don't show it. Only the ultimate recipient of the payment is reflected - regardless of whether that money passed though the lender or broker.

The broker has already paid for the report so the check would be written out to her at closing.....does that make any difference?

When you collect money that you have already paid to the appraiser for the appraisal, do you list the bank on the CD?

3. Fees “paid to” a person. For purposes of § 1026.19(e), a fee is not considered “paid to” a person if the person does not retain the fee. For example, if a consumer pays the creditor transfer taxes and recording fees at the real estate closing and the creditor subsequently uses those funds to pay the county that imposed these charges, then the transfer taxes and recording fees are not “paid to” the creditor for purposes of § 1026.19(e). Similarly, if a consumer pays the creditor an appraisal fee in advance of the real estate closing and the creditor subsequently uses those funds to pay another party for an appraisal, then the appraisal fee is not “paid to” the creditor for the purposes of § 1026.19(e). A fee is also not considered “paid to” a person, for purposes of § 1026.19(e), if the person retains the fee as reimbursement for an amount it has already paid to another party. If a creditor pays for an appraisal in advance of the real estate closing and the consumer pays the creditor an appraisal fee at the real estate closing, then the fee is not “paid to” the creditor for the purposes of § 1026.19(e), even though the creditor retains the fee, because the payment is a reimbursement for an amount already paid.

IOW, make the check payable to the broker, but disclose the ultimate recipient of that fee on the CloD.

Thank you both for your guidance!