IL Title Insurance Agent Registration Fee

I understand this is an old subject, however, during a recent audit we were questioned as to if the $3 title agent registration fee should be a prepaid item for APR?

Also, we include this fee as part of the title insurance, should this be broken out as a separate line item?

According to the Illinois Banker's association they do not think it is a PFC but we recently had an FDIC compliance exam and they believe it is a PFC. Either way the $3.00 will probably not put you outside of tolerance.

Thinking about this from a TRID perspective. Are you breaking this fee out and if so, are you putting this fee in the 10% bucket?