You need to look not at who pays the fees, but who is required to pay the fees. (I know this sounds like hair-splitting & semantics--but this is Reg. Z!!!)
Sometimes there will be side agreements between the borrower and seller. Unless these reallocations of costs are memorialized in a three-way contract (including the bank), the legal (contractual) obligation for the fees still rests on the borrower.
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...gone fishing.