Under ?? 1026.32(b)(1)(ii) (for closed-end credit) and ?? 1026.32(b)(2)(ii) (for open-end credit), all compensation paid directly or indirectly by a consumer or creditor to a loan originator, as defined in ?? 1026.36(a)(1), that can be attributed to that transaction at the time the interest rate is set, is required to be included in points and fees.