In the past we have not charged our borrowers a credit report fee. However with the recent changes to Reg Z, basically requiring us to disclose the fee anyway, we are thinking of starting to charge the borrower for it. We pay a different amount depending on the number of borrowers that we pull reports on. Can we charge any arbitrary amount we want or can we only charge what we actually pay? Example our reports cost between $4 and $8 usually. Can we charge just an arbitrary fee like $6 or $10?

What recent changes to Reg Z are you referring that requires you to disclose a credit reprot fee?

Sorry I meant RESPA. We've been under the impression even though we normally don't charge the fee we still need to begin disclosing it on the GFE, since it's a typical settlment cost.

You will either need to charge the actual amount, or use the "average" charge as described in RESPA. This requires maintaining of records...there is nothing arbitrary about it.

Thank you!!

Also, you should have always been disclosing it on the HUD-1 as POC - new RESPA or not.

We currently have the same situation where we do not charge the customer for the credit report fee. If we continue not to charge this to the customer can we use an estimated amount in Block 3 and issue a credit for the same amount in Block 2? I know we must show exact amount if we are charging customer this fee but I wasn't sure if that was the case if the bank was still paying it. We have no way of knowing the charge for the Credit report until we receive our monthly bill.