Has anyone gone ahead and started to bundle the fees charged to a residential loan customer ? My lenders want to start this procedure of charging one fee that would cover all fees currently done individually. They would show the fee on the HUD-1 and then not disclose any of the individual charges the bank paid, such as the credit report, courier fees, flood cert, appraisal, doc prep, etc, etc. They tell me many mortgage bankers are doing this already, such as ABN Amro's "One Fee" program.

Although this was proposed in the RESPA regulations, I wouldn't get in a hurry until they are finalized. Without proper itemizations, it may be hard to beat a section 8 claim. Many organizations have a "one-fee", but they still disclose all the other fees as POC.

The trouble I see brewing here is if you combine pre-paid finance charges with "other" charges in the same lump-sum, how is the consumer to know which charges are the "finance" charges if they are not itemized? I know that with certain "lump sum" disclosures, you may have an incidental fee classified as an "other" charge that would otherwise be a finance charge if disclosed separately.

However, if too many lenders abuse the practice of just disclosing a one-lump sum fee of say, $600, then we may wind up with a regulation that says the entire $600 must be considered a finance charge. It would make disclosures a lot easier, and frankly, be more truthful to the consumer about what they are really paying (4c7 never really made sense to me except to think of it as a lobbying victory by the real estate industry....), but it might bring more loans closer to the dreaded HOEPA or other state/local predatory lending triggers.