Management at my bank (in Minnesota) would like to implement a loan payoff fee of $30 or so when other creditors call and request a payoff for residential real estate mortgages as they would be refinancing our loan and taking it away from us. What are the disclosure requirements for a loan payoff fee such as this, if it is even a possibility? Is it considered a prepayment penalty? Should it be considered a fax fee to prepare and fax the payoff statement?
Thanks.