We have a newer mortgage manager on staff that comes from the broker world. He would like to change how we charge fees and instead of listing every fee out that we would be charged, we would just charge a flat fee that would cover the smaller amounts (credit report,flood determination, tax service fee and a few others) and charge the actual costs for the appraisal, title, and any LLPAs.

Are we okay to do this? I think doing it this way we're basically saying that the smaller items are lender paid.

You can charge a flat origination fee to cover those costs, but that does not exempt you from disclosing the individual closing fees and the payees paid by the lender on the CD.

It depends on how you list this particular fee

As a lender we would include the tax service fee and flood cert in our $995 lender underwriting fee. If these fees were shown on the LE, we'd remove them because we paid it. If you came up with an underwriting fee that took these fees into consideration, you could do it that way.

But you wouldn't be able to just charge a "Flat Fee" in Section B or C for a lump sum of these fees.

How would this work, Randy?
If I list individual fees as POL on the CD that were just shown as an origination fee in Section A on the LE, I'm going to get all kinds of cures because the system will look at them as new fees.

Why would your system cure a fee that is being shown as paid by the lender??