We collect our release fees at closing and hold the fees until the mortgage is released. Do we show those under Section E even though the fees are being paid to and held by the bank? I could not find anything in the reg that addressed this.

thanks.

So, you have an account that holds these fees for 15 to 30 years which you reconcile back to all outstanding loans on a monthly basis waiting for the loans to pay-off?? How do you know what the fee is going to be 10 years from now???

To add to Randy's all important questions...you will not find it addressed in the regs because it is a future fee...not a present fee.

We are not about to do the accounting requirements required for a fee like this, so when it applies, it is included as part of our loan fee.