We collect fees for flood determination, application, and appraisal at the time of loan application. These fees are reflected on the Good Faith Estimate along with all the other charges which the borrower will incur in obtaining the loan. Sometimes the fees collected up front are not labeled as POC on the GFE.

Is it a technical violation of RESPA if we reflect these fees on the GFE but do not designate them POC?

Yes. It is technical, but they should be listed as POC. This will also show the customer that they have already paid for these fees.

Also don't forget that some of these fees could be Prepaid Finance Charges that must be deducted from your Amount Financed and thereby factored into your APR. A PFC is any FC that is collected "before or at consummation of a transaction."