We are trying to properly disclose 2 fees. When refinance transactions are closed through a particular Title Co in the states of Arizona, California, Colorado, Connecticut, Florida, Georgia, Illinois, Michigan, Missouri, New York, Nevada, Ohio, Texas, Washington, and Wisconsin, 2 additional fees are charged. A National Coordination Fee of $500 and a Lender’s Division Closing fee of $500. Both fees need to be included in the APR calculation, but our system only has one available "other fee" line that will support this. Can the fees be combined onto one line for the purposes disclosing the fees on the GFE?

What are the services actually performed for these fees?

I suggest checking the language of RESPA 3500.14 and Appendix A for its instructions on how to complete the HUD-1 and 1a.

Sounds like they are junk fees assessed by the title company - my bet is that they are finance charges and have to be separately disclosed on the HUD-1. However, we definitely need more information.

Thanks....I think the issue is that our system-generated GFEs do not have enough other lines to disclose these fees separately & there is no quick fix for the foreseeable future.

Disclose in the the 1300 sereis and reference the appropriate line. We had to do this with our software a few years ago for a time until it was corrected. The FDIC accepted that solution as a temporery fix until the software was fixed.