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FHA Rate-and-Term Refinance Lender Fees
FHA refinance closing costs come from several boxes on the Loan Estimate. The only box the lender itself fills with its own charges is Section A, and that is the one HMDA records. Here is that Section A total for the 54,767 FHA rate-and-term refinances in the 2024 public record, where a quarter or more of the loans in every size band reported nothing in Section A at all.
Source: HMDA public loan data, 2024, national, FHA rate-and-term refinance, Section A total, points included.
FHA rate-and-term refinances, Section A total, HMDA 2024 data
| Loan size | 25th percentile | Median | 75th percentile | Loans |
|---|---|---|---|---|
| Under $150,000 | $0 | $2,277 | $3,894 | 3,874 |
| $150,000 to under $300,000 | $0 | $1,001 | $4,963 | 20,098 |
| $300,000 to under $500,000 | $0 | $639 | $4,413 | 23,700 |
| $500,000 and up | $0 | $1,110 | $6,143 | 7,136 |
| All sizes | $0 | $950 | $4,699 | 54,767 |
Source: HMDA public loan data, 2024, national, FHA rate-and-term refinance, Section A total, points included. Slide the table sideways to see every column.
With a $0 25th percentile, the typical range for each band runs from zero up to the 75th percentile. The median tells you where the middle loan landed inside that span.
FHA rate-and-term refinances, Section A total, HMDA 2024 data25th to 75th percentile, median marked
Typical range, 25th to 75th percentileMedianIllustrative total from the worked reading
What a $0 in this table means
HMDA's origination charges field is the borrower-paid total of Section A on the Closing Disclosure. A zero means the borrower paid the lender no origination charges at closing. It does not mean the loan had no closing costs.
Regulation Z explains the mechanism. Compensation that the loan originator receives from the lender through the interest rate is not itemized on the Loan Estimate. A lender that recovers its costs through the rate can leave Section A empty, and HMDA then records $0 for that loan. FHA also runs a streamline refinance option, but HMDA has no flag for it, so this page makes no claim about how many of the $0 loans were streamlines.
Where the mortgage insurance premiums go
Both FHA premiums are outside Section A. The upfront premium is disclosed in Section B, Services You Cannot Shop For, where the CFPB's Loan Estimate explainer places the FHA, VA and USDA upfront charges and notes that the program sets them. The annual premium is paid monthly and shows in the Projected Payments table, with any first-month amounts in the prepaids of Section F. On a refinance the premiums are charged again on the new loan, and still none of it appears in these figures.
Reading the bands
The under $150,000 band is a smaller group than the others, with 3,874 loans, and still thousands of real closings. That smallest band also has the largest median, $2,277, while the $300,000 to under $500,000 band has the smallest, $639. The 75th percentile is steadier across the bands, from $3,894 to $6,143.
FHA rate-and-term refinances next to the rest of the record
FHA purchase loans had an all-sizes median of $3,089 in the same HMDA 2024 data and FHA cash-out refinances $6,084, against $950 for the loans on this page. For rate-and-term refinances in other programs, conventional loans had a median of $1,805 and VA loans $2,755. Neither of those groups has a $0 25th percentile at the all-sizes level. These are reported totals.
A worked reading
Say a $320,000 FHA rate-and-term refinance shows two illustrative Section A lines: an origination fee of $600 and an underwriting fee of $300, for a Section A total of $900.
The loan falls in the $300,000 to under $500,000 band, where the typical range is $0 to $4,413. A total of $900 is within the typical range for that band, and it sits above the band's median of $639. The reading covers the total, never the origination fee or the underwriting fee on its own.
Common questions
A quarter of these loans show $0. Did those borrowers pay no closing costs?
No. Section A is only the lender's charges. The upfront mortgage insurance premium, the appraisal, title work, recording and prepaid interest all sit in other sections and can add up to thousands of dollars on a loan whose Section A reads zero.
Does this page cover the FHA streamline refinance?
HMDA reports loan purpose, program and loan size, and it does not tag streamline refinances. Streamlines that the lender reported as rate-and-term refinancing are inside these figures, but the data cannot say how many.
Why is the median for the smallest loans the largest in the table?
The record does not say. What it shows is $2,277 under $150,000 against $639 at $300,000 to under $500,000, with the 75th percentiles closer together.
Where your total sits
The inspection reads your FHA Loan Estimate, confirms the purpose and loan size, and grades your Section A total and your rate against this same record. If your Section A is $0, that reading is within the typical range for every FHA rate-and-term band. The method is at /methodology.
Reviewed on October 2026.
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Sources
- FFIEC, HMDA Loan Application Register, 2024 data year: https://ffiec.cfpb.gov/data-publication/ (LoanInspection percentiles at /data/mortgage-fees)
- 12 CFR 1003.4(a)(18) (HMDA origination charges, borrower-paid total): https://www.consumerfinance.gov/rules-policy/regulations/1003/4/
- Official comment 37(f)(1)-2 to 12 CFR 1026.37 (compensation through the rate not itemized on the Loan Estimate): https://www.consumerfinance.gov/rules-policy/regulations/1026/37/
- Official comment 37(f)(2)-2 (upfront mortgage insurance fee as a Section B example): same page
- CFPB Loan Estimate explainer (upfront premium under Services You Cannot Shop For): https://www.consumerfinance.gov/owning-a-home/loan-estimate/
- CFPB, What is mortgage insurance and how does it work (FHA upfront and monthly premiums): https://www.consumerfinance.gov/ask-cfpb/what-is-mortgage-insurance-and-how-does-it-work-en-1953/