If a customer was overcharged by 50 cents on a prepaid fee must we refund the overcharge and do a corrected HUD settlement statement?

The current RESPA prohibits unearned fees. The proposed RESPA states that origination fees as well as lender required and lender selected 3rd party fees have zero tolerance. We refund overcharges. If anyone knows of a HUD-1 tolerance - let me know! (even though it will be short-lived)

What if this is a commercial loan and not subject to RESPA?

we recently overcharged 40 people $1.00 for flood certs. we did not send a corrected HUD. we sent a very short letter and a check for $1.00 to each and enclosed a copy of both in the file.

If it was a commercial loan, you shouldn't have any violations.