doc prep fee that they will retain...reimburse us for our out of pocket expenses from that doc prep fee.
It would be interesting to see how this company retains a fee...but hands it to your bank. This is one of those times when it will be much cheaper to get it right the first time. Since this proposed practice would, by design, fail to disclose a FC, it would be a reimbursable pattern of violations of Reg. Z.