Answer:
Unless there is a state law restriction on the types of fees you can impose to recover costs, your bank can certainly include a "Technology Fee," either separately disclosed or as part of a general "Loan Origination Fee" in Section A of the loan estimate and the closing disclosure. You may, in fact, be already including some of those costs in an Origination Fee. If that's the case, if you want to separately disclose a Technology Fee, analyze what you are already charging in the Origination Fee and move any Tech costs over into your Technology Fee to avoid double recovery (I suggest this to avoid getting the total of the two discloses fee so large as to become non-competitive in your market). Remember that both the Origination Fee and the Technology Fee are finance charges that will affect the APR on a loan.
The bank can choose to disclose its fee for recovery of tech costs separate from its fee for other Origination costs, or combine them into a single Origination Fee (see Regulation Z comment 37(f)(1), and in particular 37(f)(1)-5 (Itemization).
print
share