Answer:
I suggest you call the CFPB for an answer. The guidance to this point has been less than clear.
Fee that's POCL: Disclose on Loan Estimate?
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Question:
If a fee is POCL, the borrower was never intended to pay for the fee, should the fee be disclosed on the Loan Estimate?
If we disclose these and the fees change (appraisal fee or credit report fee) and we adjust the POCL then it appears we are violating the specific lender credit by changing it, usually lowering the POCL fee. Should this only be disclosed on the CLoD or not disclosed at all since the borrower is not required to pay the fee?
What has confused me are these two articles/posts which make it appear if it is a POCL or lender paid fee then it does not have to be disclosed on the LE.
https://www.bankersonline.com/qa/lender-credits-loan-estimate#.V_fS_nldqlc.email
https://www.bankersonline.com/qa/new-loan-estimateclosing-disclosures#.V_fS0lp1YlY.email
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