Read the FDIC Call Report Instruction Glossary Section on Loan Fees. When I read it, there were sections that seemed clear that the answer was no and other sections were vague. Also, consider how much the loan booking area and the accounting area will hate you for all the extra work involved for a large volume of small dollar transactions that have to be entered and amortized and and and.....
Also, better get approval from your regulator to avoid having to restate the Call Report for this if they disagree.