No.
1026.38(h)(4) The services and costs disclosed pursuant to paragraphs (f) and (g) of this section on the Closing Disclosure shall be labeled using terminology that describes the item disclosed, in a manner that is consistent with the descriptions or prescribed labels, as applicable, used for such items on the Loan Estimate pursuant to § 1026.37.
How can someone confuse an underwriting fee with a fee that the borrower is paying to buy down their interest rate?
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