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Lenders constantly throw up the guideline when they think they are right...

Well as far as us billing for a draw payment, they need to ready ML 94-11

9. REVISION TO THE DRAW REQUEST FORM. Effective for mortgages closed on or after May 1, 1994, the new Form HUD 9746-A in Attachment 3 must be used on all draw requests. The Compliance Inspection
Report (Form HUD 92051) is no longer required to be submitted with the Draw Request form; however, the back side of the draw request form has been revised to include an Inspection Report that must be
completed by the fee or staff inspector on each inspection of the property during the rehabilitation period. The cost of the inspection will also be included on the back side of the form; therefore, the fee inspector
will no longer need to bill the lender for the inspection fee. The inspection report must be completed for the fee to be paid by the lender.

It appears since 1994 it hasn't been required for us to bill this separately.
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