Commercial loan disclosure

While preparing commercial loan documents, can you combine 3rd party fees with a lender fee? There is no breaking it down - just one fee that will be paid to various 3rd parties and the the bank will keep a portion of it. The borrower documents will state it is for "Disbursements".

Your thoughts????

If anything, it would be a State law issue and then you would have to worry about UDAAP, if how you are disclosing fees to commercial customers are deemed deceptive.