Answer:
If the fee is refunded, it can't be a finance charge. It should be excluded from the Final TIL.
First published on BankersOnline.com 08/18/03
TIL & Rate Lock Fees
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Question:
We charge a rate lock fee, which if the borrower closes within the initial rate lock period, is refunded at closing. We include the fee as a prepaid finance charge on the initial TIL but should we exclude it from the final since it's refunded at closing. Is this correct?
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