Disclosing Subordination Fee on GFE

Compliance > Regulation X - RESPA > GFE and HUD-1
In what block of the GFE should a subordination fee be disclosed?

HUD has not issued written guidance on this.  However, it has indicated orally that a subordination fee that is charged by another lien holder and passed through by the lender should be disclosed in Block 3.  However, any fee that may be charged by the lender for its efforts in obtaining the subordination should be disclosed in Block 1.

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