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How should an overnight fee charged by the settlement statement to the borrower be classified on the Loan Estimate/Closing Disclosure? I am aware that we cannot charge a fee for the preparation or delivery of the Loan Estimate and Closing Disclosure.
Is this an origination charge that has 0% tolerance? Or is this a charge that may be subject to a 10% tolerance assuming the borrower was not allowed to shop for the service.
If this is a charge being paid to you then it would be included as an origination charge and consider it a 0% tolerance category. If it is paid to a third party it would be disclosed in either B or C and fall into the applicable tolerance category.
Depending on your circumstances, it may fit best under “Loan Costs – C”. Also, 1026.37(f)(2) and (3) say that “for any item that is a component of title insurance or is for conducting the closing, the introductory description “Title –” shall appear at the beginning of the label for that item.”
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