Sometimes auditors and examiners can just get too focused on minutiae. Since the reg doesn't say what alphabetization standard to use, I think the criticism here is unreasonable. And, BTW, if the same costs were listed in the same way on both the LE and the CloD, they should appear in the same order on both (unless you're creating them one two different systems).
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8