In our SFR 1-4 consumer construction lending the bank's policy is that the 12 mo const loan is scored through a scoring module that pulls a single repository file. Since this is SFR and will be sold into the secondary market, our policy also requires that a tri merge report is pulled at the same time to ensure all three repositories are considered and the end loan is not in jeopardy. I can't find anything that says we can't charge for both services. They both played a role in the approval. However, if we've ended up with two charges on other types of loans (usually because of human error) we've only passed the accurate or initial charge onto the borrower. I don't want to be UDAP'd but this is a real credit exposure risk that we are trying to avoid. We don't want to tell the customer at the end of their construction period that their score in one system is insufficient for the secondary market. Is this a cost that has to be passed on in origination fee. If I can only charge the borrower for one - can it be the more expensive bureau?

Allowable loan charges are a State law issue.

I appreciate your guidance - I've researched the two state codes in our lending area for consumer and mortgage lending, and Reg X is where it becomes problematic. The instructions say that "Line 805 is used to record the fee for all credit reports". I can't lump to different payees on the same line....

I can't find anything that says I can't have two separate vendor names in the paid to section with itemized fee in side and the total in 805. But my software offers 808 as an additional credit bureau fee as a dropdown option for iine 808... which if you are to read X it says all must be in 805.