BDyess,
The RESPA Roundup is something that you have to comply with. There are a couple of ways that you can approach this. The RESPA Roundup doesn’t explicitly say that if you deliver the GFE late, that you have to list the fees as $0 on the HUD, in the comparison chart. It mentions that if a GFE is not delivered at all, that the fees would then have to be treated in that manner.
Some hold the belief that since it references the section of the regulation that talks about being delivered within three business days from the date of application, that not delivering it in a timely manner also would constitute listing the fees on the comparison chart as $0. If you want to be ultra conservative, you could abide by this approach and you should not be criticized by regulators. That being said, if you choose to take the approach that you don’t have to do so, as long as a GFE was given (timely or late), then you still may not be criticized, but realize that it is a possibility. It depends on your institutions appetite for risk in this area.
I personally think you’ve got a good argument, or at least could make some good points, by saying that you don’t have to list the items as $0 on the comparison chart, as long as a GFE was delivered.
As for your questions not being answered yet, if you asked HUD, I doubt, you’ll ever get an answer as RESPA is the CFPB’s baby now. You might not get an answer from them either at this point, as they are making some massive changes to RESPA, and we can only hope those changes will make things clear than what we have to deal with at this point.