We don't disclose who the recording fee is to on either the HUD form or the GFE. I would like to know if we should. However, according to Reg Z 226.4(e)(1), (e) "Certain security interest charges. If itemized and disclosed, the following charges may be excluded from the finance charge:
(1) Taxes and fees prescribed by law that actually are or will be paid to public officials for determining the existence of or for perfecting, releasing, or satisfying a security interest."
It appears that if we are not disclosing who they are to, we should be disclosing them as finance charges then. Is this correct?