Fees on LE

Do you charge fees on LE to your customers that you know from beginning that bank never will never require?

If you are, you are in violation, as your LEs are not being issued in good faith.

That's call fee padding and as Randy stated that is a blatant and willful violation of the regulatory good faith standard.

That is how I see it. Just making sure. Thanks for your help.

Not only could it result in a citation for Regulation Z and Truth in Lending violations, but also it could require a full refund of all closing costs to the borrower. It could also raise questions about the bank's overall compliance program.