Answer:
The portion payable to the government entity to perfect the lien would be exempt if properly disclosed. The portion paid to the 3rd party for processing the transaction would be a PPFC.
Excluding Filing Fees from Finance Charges
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Question:
A UCC filing fee paid to a government entity to perfect a security interest in a consumer product must be listed in the Fed Box to avoid being a finance charge and included in the APR. Our filing fee is paid to a non-government third party vendor. Because of this third party involvement, our compliance department feels the fee should not be listed in the Fed Box. If all or a portion of filing fee we charge to the borrower will be paid to the government entity I feel that portion should be noted excluded from the finance charge and APR. Do you agree?
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