I am looking for some guidance on charging credit report fees on real estate loans. In a recent review, I have noticed where we are charging borrowers for more than one credit report because for one reason or another, it was necessary to pull another report. However, I only see the new credit report in the file.

They are throwing the other ones away?

Then that leaves they are charging for reports never ordered? I guess I do not understand your question then?

We have internal procedures regarding the allowable age of the credit report at closing. If we need to obtain a fresh report (due to expiration of the first one), we keep both reports with the loan file. I also have admin rights, so I can obtain a billing report if we have questions. We do not charge the borrower if we can't document the validity of the charge.

Thank you.