I have a title company that is including credit card payoffs/debt consol. in section L of the HUD1. I don't think these are "settlement services" as defined by RESPA. (Not to mention the fact that it makes our settlement fees look like an SUV purchase.) It seems to me if they are paid out of the loan proceeds they should be listed on line 104. Anyone else experiencing this?

We are not experiencing this problem with our title companies, but I agree they should be listed on 104 or 105.

Ditto. Sounds like the title company has confused RESPA and the HUD-1 with the Truth in Lending itemization of the amount financed. But, TIL specifically says that the HUD-1 replaces the itemization. And you fill out the HUD-1 to comply with RESPA. At this point, Reg Z has no say in what goes on what line of the HUD-1.