When the closing attorney needs to Fed Ex a package which includes bank documents should this Fed Ex fee be considered as part of a finance charge?
If a customer pays the appraisal fee prior to closing should that fee disclosed as a POC and does it affect TIL?
Should I split the Flood Certification fee because of the APR or do I have to split it on the HUD?
When charging a document preparation fee on a consumer loan is the fee disclosed as part of the finance charge and not added into the principal?
Here are a few details before the question: A Cash Reserve line of credit that is tied to the customer's checking or money market account only and the Line of credit (in increments of $100) is advanced only when funds are not in the checking account. Here's my question: The Business line wants to start charging a $10 transaction fee for each draw/advance and the $10 fee will be coming from the line of credit, not the checking account. Is this transaction fee a finance charge?
Regarding Paid Outside Closing fees (POC) on a HUD settlement statement, if the fee is listed as POC on the HUD settlement can it be included in prepaid finance charges? I came across a HUD with POC listed after a credit report fee and flood certification fee, but the fee is included in prepaid finance charges.
Can you tell me where I can learn the disclosure requirements needed when credit insurance is purchased by a customer?
I am an assistant manager at an in-store branch. The bank compliance officer tells me I can't advertise our mortgage or auto rates without disclosing the APR. It was my understanding that this must be disclosed when actually PROCESSING a specific loan. I thought I had seen newspaper ads w/o the disclosed APR. He told me they were probably mortgage companies. Is he correct? Must we disclose the APR even in advertisements? If so, are there restrictions on HOW it is disclosed, such as spreading the fees over the life of the loan vs. using the first year only (which makes the APR higher)? Are there any fees that we can leave out of the APR?
I have looked at several manuals for Reg Z. Can you give me a clear definition of what a prepaid finance charge is and is not, and what makes it a prepaid charge?
Regarding Reg Z, 226.4(d)(2)(i): If a home is in a flood zone, would the flood insurance premium need to be included in the Finance Charge on the TIL? Would the disclosure need to be signed by the customer? And what specific terminology needs to be added about the customer's choice to choose their flood insurance?