On a coach only mobile home loan (no land, no TRID), we charge points. We also absorb (pay) for certain fees - like a filing fee. For the TIL Disclosure, 1026.5(e) says that in order to exclude filing fees from the finance charge, we need to itemize and disclose the fee. My thought is that we are not charging the fee to the borrower (directly), so we do not need to disclose it on the TIL. But the rule says if not disclosed, it cannot be excluded from the finance charge and the APR calculation? Would we be correct to not disclose it at all?