We had a $22 employment verification fee disclosed on the LE. When we produced the initial CD the fee dropped off. In the process of creating the final CD we realized the verification fee was missing. Are we permitted to put the verification fee on the final CD and charge the customer since it was on the initial CD or must the bank pay the fee?

Under the TRID rule you should have no problem adding the fee back in on the final CD if it was on the most recent LE, but some investors will not accept that. Under the TRID rule the final CD is compared to the LE to determine tolerances but some investors will determine tolerances by comparing the final CD with the previous CD.