I think I understand this, but I want to post here for confirmation...

Fees charged and collected can not be more than lifetime cap of 3%. So, we disclose all our origination charges as they stand. (Even if they total over the 3% cap)... and then I show them as lender paid expense in block 2 to get get to the 3% range?

Do I understand this right?

Will be curious as to others' responses, but that is how we are doing it. Another example is that there is a requirement for home equity (and I think maybe all second liens) that appraisal fees cannot be charged to the consumer unless they are conducted by a certified appraiser. We have a 3rd party who does evaluations for us, but he's not a certified appraiser, so we list the fee in block 3 of the GFE and line 804 of the HUD-1, but make it a block 2, line 802 credit.

It would be extremely rare that we exceed the cap, but that is how we would do it. We obtain broker opinions for most home improvement and home equity loans so it's easy to stay below the cap. Those cost about 100 bucks.

That's pretty much all we do in terms of H.E., we don't call them broker's opinions. We call them Market Evaluations - but ours cost $150. Attorney's Fees are $250. Settlement Fee of $250. You can see how that adds up fast.

No attorney fees....we prepare our own docs....no settlement fee...we close'em in house.