Where to List Doc Preparation Fee on GFE

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Question:

We have just had a compliance exam and they said that we have included the document preparation fee as a prepaid finance charge. We are listing it on the GFE in origination fees. Is this not right.? If not, where do you put it on the GFE?

Answer:

You are correct. Document preparation fees would be listed on the bank origination fee line on the GFE. However, under Regulation Z they would be excluded from the finance charge. Don't mix the RESPA and Regulation Z requirements, as they are not the same.

First published on BankersOnline.com 10/8/12