|
Puzzled by the OCC's Handy Chart
by Dan Persfull, BOL Guru
Guru Bios
Question: Recently I came across a thread that recommended looking at the OCC's Comptroller's Handbook for a handy chart of what is a finance charge, and what is not. In the CHARGES NOT INCLUDED (residential mortgage transactions, and loans secured by real estate) column, I found that fees for preparing loan documents are not finance charges, and should not be calculated into the APR on those types of loans. Do I understand this correctly? Are document fees or document preparation fees not finance charges in regards to residential mortgage/loans secured by real estate?
Answer: If they are bona fide and reasonable, they are exempt from the finance charge for real estate secured loans. The key is bona fide and reasonable. If you charge a $500 document preparation fee, then you better be able to document that it costs you $500 to prepare the documents. By the way I am FDIC regulated, not OCC.
First published on BankersOnline.com 3/13/06
Privacy Policy Disclaimer Recommend This Site ! Contact Us
BankersOnline is a free service made possible by the generous support of our advertisers and sponsors. Advertisers and sponsors are not responsible for site content. Please help us keep BankersOnline FREE to all banking professionals. Support our advertisers and sponsors by clicking through to learn more about their products and services.
|
|
|
Print Friendly!
Email This Article!
Discuss NOW!