This also dovetails into the markup restrictions. If one has a courier fee of $20.00 and adds a $10.00 fee for preparation and delivery of the package to the courier does that constitute a nominal or worthless fee? And does it violate the markup prohibition?

It seems to me this is a real can of worms. It is made worse by the fact that the GFE may quote amounts above the actual charges. Therefore, moving the actual charges to the GFE quote amounts borders on markup prohibition and charging nominal or worthless fees. But then the GFE quoted amounts could only be considered bogus whenever they are higher than the actual lowest charge available to a consumer in the marketplace.

I don't believe there can be any decisiveness in Freeman. It may come to rest more on HUD's rule-making authority than trying to decipher the moving-target dynamics of pricing within real estate settlements!

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