Looking for clarification please: We currently place Title Updates to Title companies for construction loans in section A of the LE and do not subtract it when calculating the total loan amount. Our new LOS does subtract it for TLA. Re-thinking this, I guess it is correct to subtract because we are not retaining.

Additionally in researching I am now questioning whether this fee even belongs in A. The chart I have from ppdoc's, I believe from the description(Title-All services provided) has it in section C.

Since title updates - I assume these are date down endorsements - are third party charges and you know the third party to which these are payable, then yes - they would be Section B or C charges, as applicable. They would also be prepaid finance charges, similar to any post closing inspection fees..

They are not date down endorsements, they are just updates from the time the mortgage is recorded to the time of the draw requests.

My thought is because we have the title in section C on the LE this fee should also be in C, with the potential to move to B.

And because we do not retain this fee, then it should be subtracted for purposes of determining total loan amount for QM?