Closing Agent Fees: CPL, Notary, Courier, Wire

B or C: the written list decides

Whether these lines sit in Section B or Section C depends on whether the lender let you choose the closing agent. If the lender permits shopping, it has to give you a written list of providers and tell you that you may choose a different one. The CFPB's commentary lists the closing protection letter fee in both of its example lists: Section B when you could not shop, Section C when you could. The section also sets the tolerance:

The 10 percent test applies to the group rather than to each line: the shopped services and recording fees on the Closing Disclosure, added together, may not exceed the same lines on the Loan Estimate by more than 10 percent. One line can rise more if another fell.

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Row by row

Title - Closing Protection Letter (CPL). Also called an insured closing letter. The title insurance underwriter, meaning the company behind the policy rather than the local agent, issues it to the lender. In it the underwriter agrees to cover the lender's actual losses if the closing agent steals or misapplies funds, or fails to follow the lender's written closing instructions in a way that affects the title or the lien. Lenders require it before they release the closing package. In some states the letter also protects the buyer, and in some states the charge is set by statute or by the insurer's filed rates.

Title - Notary fee. The mortgage or deed of trust, and the deed in a purchase, must be notarized to be recorded. The agent's staff notary handles it at the closing table, or a mobile notary, often called a signing agent, brings the package to you. On the sample it is $150 in Section C. If your closing uses remote online notarization, a platform charge may appear as its own line under the same prefix.

Title - Courier, overnight or messenger fee. Signed originals go to the lender for funding review, payoff checks go to a prior lender, and documents go to the county. Electronic recording and e-signing have cut the shipping, but many closings still move paper. The CFPB sample forms print no courier line; it appears when the agent charges it.

Title - Wire fee. The bank charge for sending outgoing wires: loan proceeds to the seller or a prior lender, and any amount back to you. It is usually charged per wire. The CFPB warns that closing wires are a target for scams. Its advice is to confirm wire instructions with your closing agent by phone, using a number you already had, and never to follow instructions that arrive by email.

Title - Disbursement or funding fee. The agent's charge for paying everyone out of the closing funds: balancing the file, cutting checks, sending wires. Some agents include it in the settlement fee and some break it out. It is different from a funding fee the lender charges in its own name, which is Section A, and from the VA funding fee, which is a government program charge.

Title - Settlement or closing fee. The agent's main charge for conducting the closing, and the line where courier, wire and disbursement charges often get folded when they are not listed separately. On the sample it is $650.

Title - E-recording or recording service fee. The county's charge for recording the deed and mortgage sits in Section E, because it is paid to a government. A service charge from the agent or an e-recording vendor for submitting the documents electronically is a third-party service charge and sits with the other closing agent lines.

Attorney fees at closing. In states where an attorney conducts the closing, the attorney's fee is the settlement fee under another name and follows the same B or C logic. Two neighbors are easy to confuse with it: a lender's attorney fee, which the commentary places in Section B, and a document preparation fee the lender charges in its own name, which is Section A and covered on the administration fee page.

Names on the two forms