Charlene,

I would think from your perch you will see some very clever accounting. It always amazes me how the numbers can be camouflaged. And the GFE/HUD, as you point out, makes it indecipherable to most borrowers how the numbers are derived.

On the originator issue there were questions of whether employers of loan originators could make contributions to 401(k) and stock ownership plans. You can imagine other types of profit sharing arrangements designed to exist under the radar. The FED seems aware of these as they described them as "problematic". My point is you may see what you describe still existing within loan originator employees!

And the larger point is that with all this GFE/HUD transition, Dodd-Frank, Reg Z Amendments and the impending CFPB, borrowers are still getting whacked!