Adding Fees into MAPR Calculation (Exclusions)

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Question:

Other than the specific fees listed in 232.4(c)(1)(i)-(iii), do we have to add fees into the MAPR calculation that would otherwise be excluded from the finance charge? For instance, for a vehicle title loan fees excluded under 1026.4(e)(1) or for a land only loan fees excluded under 1026.4(c)(7)?

Answer:

No. You start with the finance charge elements as prescribed by Regulation Z for the loan in question and then add the specific fees listed in section 232.4(c)(1)(i) - (iii). As noted in section 232.4(c)(1)(iv), you add in a fee listed in (i) - (iii) even if it is excluded under Regulation Z.