Frequently Asked Questions


Fees Keys is a simple self-auditing tool that identifies fraudulent mortgage fees (i.e. closing costs, junk fees).

Fees Keys incorporates all of the pertinent regulations:

  • 12 Code of Federal Regulations Part 1024 (Real Estate Settlement Procedures Act, Regulation X)
  • CFPB's Integrated Mortgage Disclosure Rules
  • 38 Code of Federal Regulations 36.4313
  • Department of Veterans Affairs (VA) Pamphlet 26-7, VA Circulars, and Guidelines
  • State Fees and Charges Deviations

Consumers benefit by identifying fraudulent mortgage fees (i.e closing costs, junk fees) that they may recover.

Lenders benefit by building an unparalleled reputation of trust and confidence for their customers and their brand.

Regulators benefit by leveraging consumer and lender participation in the enforcement of mortgage regulations.

Given that:

  • Consumers pay close to $1 Billion in fraudulent mortgage fees every year.1
  • 1 in 6 mortgages have fraudulent closing costs, averaging $910.2
  • Combined, regulators audit less than 1% of ALL mortgages.3

Yes, there is a need.

Junk fees, while considered immoral, are not necessarily fraudulent. They are fraudulent only when they violate regulations, which they may by themselves or when charged in combination with other fees.

Fees Keys can be used for any VA, FHA, or Conventional mortgage, to include:

  • Purchases,
  • Refinances,
  • Cash-out Refinances,
  • Streamlines or (IRRRLs),
  • Native American Direct Loans (NADL)
  • Construction loans,
  • and even Jumbo mortgages!

Absolutely. Even though your original lender no longer "services" your mortgage, they are still responsible for regulation compliance of your mortgage.

Yes, your mortgage contract requirements are not absolved during the term of the mortgage for either you or your lender. Thus, you can be in the last year of a 30-year mortgage, and your originating lender is still obligated to comply with the regulations.

No, they may NOT. Lenders are permitted to "pass-on" third-party fees, but they may NOT increase them.

No, Fees Keys is simply providing a service to empower all mortgage participants (consumer, lender, and regulator) to ensure regulation compliance.