If recording fees are itemized and disclosed, and the loan is between the borrower and bank, wouldn't the fees be excluded from the finance charge? I see that the commentary states that if the obligation is between the creditor and a third party (an assignee, for example) recording fees are not excludable. Does obligation mean the loan, from whom the fee is paid, in other words, whether the fee is paid from the loan by the bank (if financed) to the county versus paid from the loan (if financed) to the settlement agent/3rd party who then pays the county?

Regardless of who pays them - you or the settlement agent, they would be listed in Section E of the CD and not be included. That is referring to if you are charging the borrower to record an assignment between the bank and someone purchasing the loan, it would not be excluded as it is not related to the consumer's loan.