We charge a "Doc Prep Fee" on all consumer loans. When should the Doc Prep Fee be listed as a Finance Charge, and when should it not?
I've reviewed different banker threads with various responses. As I understand Reg Z, a Doc Prep Fee is not considered a finance charge for RE credit transactions. But, in Minnesota, it is? We currently do not include as a Finance Charge for any consumer credit transaction, and will refund any portion necessary if paid off early. I'm thinking this is not accurate? Please help!