We're contracting with a third party to pay title fees to the state. Can we show the fee as a single item on the itemization of amount financed or do we need to split out the amount that they charge for the service from the amount that is paid to the state? These are not real estate secured, so they're not covered by RESPA.

Thanks,

Only the fees actually paid to the state for the title fees are exempt from the finance charges if properly disclosed. The fees paid to the 3rd party for providing the filing service are pre-paid finance charges and will have to be disclosed as such.