Exclude Organization Fee from Finance Charge TILA

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Question:

If part of line 801 "Origination Fee" is broken out as Doc Prep Fee, can that portion be excluded from the Finance Charge for TILA?

Answer:

Regulation Z, not RESPA, determines what charges you can exempt from the finance charges. 1026.4(c)(7) exempts document preparation fees for real estate secured loans if they are reasonable and bona fide.

First published on BankersOnline.com 4/16/12