This section applies to loans not exceeding $50,000. It says you can charge up to 18% APR, and also charge the lesser of $50 or 2% of the loan. This means that the $50 or 2% can be excluded from the FC and calculation of the 18%.This charge is for "investigating the character and credit of the person applying for the loan, the security submitted, and the costs of booking the transaction." You can probably also charge a separate doc prep fee (may not be included in the costs of booking the transaction - but not sure how would be interpreted by an examiner) as long as you include this $200 as a PFC and the APR does not exceed 18%. You cannot exclude the $200 from PFC. It is simpler and safer to include both of these charges as PFCs and watch the APR to be sure it does not exceed usury.