I can answer your question about disclosing the recorder's fees on the CloD because I asked a similar question back in September, in this thread:
https://www.bankersonline.com/forum/ubbt...ion#Post2039345This is the portion of the webinar mentioned in the thread, too:
CFPB Webinar 11/18/2014:
Walton-Fein: Yes, David, we have received a few questions about the taxes and the other government fees part of the disclosure. So, first we have been asked: How does the disclosure of recording fees differ between the Loan Estimate and the Closing Disclosure?
Friend: Well, the Loan Estimate requires the sum of all recording fees to be disclosed as one item. The provision for that is found at § 1026.37(g)(1)(i). The Closing Disclosure also requires the recording fees to be disclosed as one item, but also requires that the amount paid to record the deed and mortgage be itemized separately. The itemized recording fee for the deed and the mortgage should only include the amounts needed to record each of those documents. Recording fees associated with any other documents, except for the deed and the mortgage, are just included as part of the total recording fees and are not separately itemized. See § 1026.38(g)(1)(i). Please note that the total recording fees are allocated between the consumer, seller and others in the applicable column pursuant to the agreement among those parties.
Walton-Fein: Thanks, David. We've also been asked: How should creditors disclose the name of the government entity to whom a transfer tax is distributed?
Friend: So creditors should disclose the name of the entity assessing the transfer tax, even if that is different from the payee of the check cut by the settlement agent. State and local governments collect transfer taxes in many different ways, and sometimes the checks for the payment of transfer taxes are not made out to the entity actually assessing the transfer tax. However, this fact is irrelevant for purposes of the Closing Disclosure, the governing authority assessing the transfer tax must be disclosed, along with the amount paid by the consumer, the borrower, seller and others. See 1026.38(g)(1)(ii).