Q: What does it mean to impose a fee?
A: A fee is imposed by a person if the person requires a consumer to provide a method for payment, even if the payment is not made at that time. (Comment 19(e)(2)(i)(A)-5)
This would include, for example:
Note: As discussed above (in the Bureau’s compliance guide), a creditor or other person may impose a bona fide and reasonable fee before the consumer receives the Loan Estimate, if the fee is for purchasing a credit report on the consumer. (§ 1026.19(e)(2)(i)(B))