Is it possible to pass on an extension fee with the Initial closing disclosure? It seems to be allowed if its incurred seven days before consummation. Would this be allowed if there is more time then seven days between the initial closing disclosures and consummation?

Extension fee?? What sort of extension fee?? Rate lock extension?

You have three business days to re-issue a LE or a CloD under 1026.19(e)(4)(ii) from the date the extension was entered into.

Yes a Rate lock extension. This would be with in the three day timeline. Thank You for your reply.

At the time you prepare the initial closing disclosure, you should typically know whether a rate lock extension will be needed based on the estimated closing and funding date (and your investor lock policies). If it will be needed, extend the lock and disclose an extension fee on the initial closing disclosure.

But an extension fee is a zero tolerance item. Why would you put it on the CloD if doing so only causes you to cure it?

If you have a valid changed circumstance for the rate lock extension, before you've issued the initial closing disclosure, you can reset your tolerances with a revised loan estimate or the closing disclosure (if there are less than 4 business days between the time a revised LE would have been required prior to consummation).

I know it's a valid CC and an LE can be redisclosed but that's not the question posed by the OP.
Can you add an extension fee to the initial CloD was the question.
And my answer is still sure but why would you want to when doing so is cause for a cure.

If you have a valid changed circumstance, can't you add the extension fee to the initial Closing Disclosure to reset your tolerances- if there are less than 4 business days until consummation?

If the timing is such that you haven't yet sent the CloD but can't issue a revised LE, you can issue the CloD and it fills the role of the revised LE to the extent that you disclose the added rate lock fee. What it cannot do for you -- and it's not a problem -- is provide the revised rate lock expiration date.

Maybe it's the holiday today that has me off kilter but this isn't going into my brain right today.
If I add the extension fee on the CloD, how do I not have to cure for it because it's a new fee that wasn't on an LE?

I answered it above. It all depends on when you find out that a extension fee is going to be required:

"You have three business days to re-issue a LE or a CloD under 1026.19(e)(4)(ii) from the date the extension was entered into."