"Flat closing cost bundle"?

One of my favorite types of questions came from the mortgage department this morning:

They heard on some webinar an attorney say that there is nothing in the reg that would prohibit us from charging a flat closing cost fee bundle. They would like to disclose it as one item under the Services You Cannot Shop For.

I am seeing plenty in the reg that specifically requires itemization, but just wanted to check if there is something else that I am missing?

So, if it is a service they can shop for - which vendors in your area offer a single charge no matter what is required??

Apparently now we itemize the costs under the services you cannot shop for anyway and just eat the the difference if there is any in the end. Everyone gets the same prices quoted that add up to the advertised closing costs.

just eat the the difference if there is any in the end.

By eat the difference, I hope you mean that you provide an appropriate cure. You can't not disclose the actual costs.

There's nothing in the regulation allowing you NOT to itemize the actual charges on the CloD. And that will cause all sorts of problems for you in calculating the cure, since you will have charges for which you provided no estimated amount.

Just don't go there!