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#586191 - 07/20/06 05:15 PM Reg Z Reimbursement?
starfish Offline
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starfish
Joined: Jun 2003
Posts: 416
Seattle
If we have a situation where we are doing an appraisal or inspection that is to be done prior to closing (thus eliminating the fee as a finance charge) but then was inadvertently not done until post closing, would this be a Reg Z violation? The Final TIL does not include the fee as a finance charge. It's obviously a problem that this was a condition of the loan prior to funding but I'm just trying to figure out if we have a reimburseable situation.

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Lending Compliance
#586192 - 07/20/06 06:08 PM Re: Reg Z Reimbursement?
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
I would treat this as snafu in the process and not look at it as a regulatory violation. However, if it became the rule and not the exception then I would be finding out what's going on and advising them the fee would have to start being treated as a finance charge because of their practice.
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The opinions expressed are mine and they are not to be taken as legal advice.

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