Is there a requirement in 1026 that financed closing fees must be listed on the first statement using the same terminology as that on the closing documents? I see in 1026.7 that a "finance charge" must be listed as such on the statement. But, I don't see that a "recording fee" or "flood determination" must be spelled out using identical terminology. Our statements have limited description space, so we are not able to spell out "finance charge: documentation fee" as an example. Is it acceptable to list "finance charge: doc fee"?

1026.5(a)(2)(i) Terminology used in providing the disclosures required by this subpart shall be consistent. Commentary to that says: 4. Consistent terminology. Language used in disclosures required in this subpart must be close enough in meaning to enable the consumer to relate the different disclosures; however, the language need not be identical.

You will be at your examiner's mercy when deciding if the terminology is close enough in meaning to enable the consumer to relate the application disclosure, initial disclosure, and periodic statement. I would recommend trying to stay identical if possible.

Commentary to Section 1026.7 also gives valuable information when disclosing "other fees" such as recording charges.

Just FYI on the flood determination...the cost of the life of loan coverage is a finance charge if you get life of loan coverage with the flood determination.

I've had issues with two different LAS which were not able to properly (without a lot of work arounds) disclose financed closing fees on the first statement correctly. We finally decided to either eat all the fees (during promotions), or require all the fees paid in cash.