When a loan is increased with a modification aggreement and fees are charged for appraisal, title services, and modification doc prep how do these fees need to be disclosed?

If it not a refinance under 226.20, there are no disclosure requirements, unless governed under State law.

But they have to be disclosed right?

OK - let's try again:

If it not a refinance under 226.20, there are no disclosure requirements, unless governed under State law.

That said, I would think that somehow you probably want to ensure that your customer is aware of such fees as a customer service and to prevent some sort of misunderstanding.

When a HELOC is being increased through modification and the fees are taken out as draws do they need to be itemized on the next statement the same way initial closing fees are?