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Is it permissible to include the credit report fee as part of a processing fee on the LE and/or CD, or are we required to break it out?
I assume you are requiring the service and it is being paid to a third party so it must be itemized on the loan estimate.
1026.37(f)(2):
Services you cannot shop for. Under the subheading “Services You Cannot Shop For,” an itemization of each amount, and a subtotal of all such amounts, the consumer will pay for settlement services for which the consumer cannot shop in accordance with § 1026.19(e)(1)(vi)(A) and that are provided by persons other than the creditor or mortgage broker.
Also, the October 2014 CFPB webinar addresses the requirement to itemize fees paid to their parties in a question about fees that might have been rolled into the origination charge.
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