Well, you have this commentary below. But relying on it when you really do not have any idea of the exact services the charges actually represent is somewhat dangerous. Plus, an overstated F/C or APR is never a violation when dealing with a mortgage loan. The rule of thumb is, if in doubt, just include it.
Official Interpretation
4(c)(7) Real-Estate Related Fees
2. Lump-sum charges. If a lump sum charged for several services includes a charge that is not excludable, a portion of the total should be allocated to that service and included in the finance charge. However, a lump sum charged for conducting or attending a closing (for example, by a lawyer or a title company) is excluded from the finance charge if the charge is primarily for services related to items listed in §1026.4(c)(7) (for example, reviewing or completing documents), even if other incidental services such as explaining various documents or disbursing funds for the parties are performed. The entire charge is excluded even if a fee for the incidental services would be a finance charge if it were imposed separately.
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