Section 1026.40(d)(8) required an estimate of the total fees imposed by third parties to open an account. We do not itemize the fees unless the consumer makes a request. Do we need to have support for the dollar range that we disclose?

The section of the the regulation you reference refers to a need for a good faith estimation of the fees. Not sure how the estimate could be in good faith if you don't have any support for the numbers you are using.

I agree with you. I'm looking at our HELOC for the first time and the high end of the range seems out of whack. At previous banks I have worked for the fees were itemized and the low/high matched the range disclosed. Not sure why we have chosen to not itemize. I guess I know what I'm doing today.