We have several loans where the loan costs are financed in with the loan. We recently had an audit and received a finding for our calculation of total payments in five years on our Loan Estimates that include financed loan costs. The auditor states that we need to double count our financed loan costs = principal balance (including financed loan costs) + interest + loan costs. We utilize Laser Pro for our lending so we are reaching out to them to see if they have been contacted by any other institutions that have had this same issue but also wanted to get guidance here. Any feedback I can share?

Paragraph 37(l)(1)(i).

1. Calculation of total payments in five years. The amount disclosed pursuant to § 1026.37(l)(1)(i) is the sum of principal, interest, mortgage insurance, and loan costs scheduled to be paid through the end of the 60th month after the due date of the first periodic payment.

So, that equates to your total of P&I payments made in the first 60 months, any odd days interest paid at closing, any mortgage insurance payments made in the first 60 months and the total loan costs from Section D..