Sec. 226.17 General disclosure requirements.
(c) Basis of disclosures and use of estimates. (1) The disclosures shall reflect the terms of the legal obligation between the parties.
(6)(i) A series of advances under an agreement to extend credit up to a certain amount may be considered as one transaction.
(ii) When a multiple-advance loan to finance the construction of a dwelling may be permanently financed by the same creditor, the construction phase and the permanent phase may be treated as either one transaction or more than one transaction.
I may be missing something but I do not see how the above section exempts the ½%, I do not think you cannot count the ½% fee paid to the other FI as PPFC. To me it is a fee associated with obtaining the loan, thus a PPFC.
As for you giving disclosures for the permanent phase of the loan, that is not your responsibility. You are not doing the loan, therefore you have nothing to disclose in relation to the permanent loan.
The opinions expressed are mine and they are not to be taken as legal advice.