Answer:
That depends. Reg Z specifically excludes from the definition of finance charge some real estate related fees when the fees are bona fide and reasonable in amount. These fees excluded include fees for many services typically performed by an attorney in a real estate lending transaction such as fees for title examination, abstract of title, title insurance, deed and mortgage preparation, and reconveyance or settlement documents. Fees for other types of attorney charges or fees for attorney charges in a loan not secured by real estate would not be specifically excluded.
First published on BankersOnline.com 2/4/02
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