Here's one that has me scratching my head:

I work for ABC National Bank, which has branches all over the state. There is already an ABC National Bank in one of the cities that we have a branch in, so we are dba XYZ National Bank in that city. XYZ is not a separate entity in any way.

ABC National Bank took a mortgage app and took it to underwriting. We found out we couldn't sell it secondary market and would have to take it in house. ABC sent the information to XYZ to prepare the docs and close the loan, since the property was in that city.

XYZ discloses the credit report fee on the HUD as going to ABC National Bank and not our credit bureau servicer. ABC did pull the report before sending the package to XYZ.

Is this right? Ultimately, the credit bureau servicer is the one getting paid. But XYZ maintains that ABC needs to pay them and not XYZ since ABC is the one who pulled the report. But since we are all the same bank anyway - legally and regulatorily - and the money is all coming out of the same pocket, shouldn't the credit bureau servicer be the one on the HUD?

I'm so confused!

Short and simple - the CRA's name should appear on the HUD.

Thanks Dan. I was hoping you would be the one to answer me. I thought it should be the CRA, but needed an expert opinion.