We have had new compliance auditors recently, and I am now confused about the 10% tolerance category. Two questions (1) Filing fees are included in the 10% tolerance category, correct? and (2) Are the 10% items calculated on the TOTAL of Services you can shop for and the recording fees, or are they calculated on each individual line item within that "bucket?" Our new auditors have required that we refund some items for title charges, because the individual LINE ITEM within the title fees were more than 10% over our estimate, but the TOTAL title charges were under, AND, have had us cure a filing fee for the fee being $52.00 on the CD rather than $50.00 as per the LE.

1) Yes, filing (recording) fees are included.

2) It's the total, not individual line items.

Ask your compliance auditors for a citation

If they find one, they made it up

Lol, THANK YOU!

FYI - there is a per line tolerance issue (0%) if you don't allow your borrower's to shop. It sounds like they are getting confused.

But recording fees are always in the 10% group. Document excise (tax) stamps are always 0%.