Answer:
Your analysis is sound. Reg Z describes numerous fees that can be excluded from the finance charge. The real estate exclusions in 226.4(c)(7) are very specific and appear to apply to your situation. Fees, such as your appraisal and credit report fees, can be excluded from the finance charge if the transaction is secured by real property or if the transaction is a residential mortgage transaction and if the fees are bona fide and reasonable in amount.
First published on BankersOnline.com 3/4/02