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#1199367 - 06/11/09 01:42 AM Non-refundable application fee
complyyes Offline
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Joined: Apr 2006
Posts: 51
Midwest
Our bank charges a non-refundable application fee that we do on occasion refund. Is it included in the finance charge? The Reg. Z finance charge chart says Yes but that an exception is if it is charged to all applicants. Then no. We do charge all applicants but occasionally refund. Should it be included in the finance charge?

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#1199386 - 06/11/09 11:33 AM Re: Non-refundable application fee complyyes
rlcarey Offline
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rlcarey
Joined: Jul 2001
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Galveston, TX
Yes, because you do not charge all applicants the fee since it is occasionally refunded.
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#1199414 - 06/11/09 12:33 PM Re: Non-refundable application fee rlcarey
complyyes Offline
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Midwest
Thanks.

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#1199806 - 06/11/09 05:34 PM Re: Non-refundable application fee complyyes
Richard Insley Online
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Richard Insley
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Toano, VA
Apply the same strict standards as for pregnancy: yes or no - no gray area. The moment you refund the first "non-refundable" fee, you change all subsequent fees (and possibly the ones excluded in the past) into FCs.
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#1225479 - 07/31/09 12:54 PM Re: Non-refundable application fee Richard Insley
pacar Offline
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Posts: 320
Newbie question:
So if a fee is considered refundable, it is not included as a Finance Charge? How do we determine if a fee is refundable or not?

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#1225486 - 07/31/09 01:00 PM Re: Non-refundable application fee pacar
Skittles Online
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Skittles
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TN
If it is refundable it IS included in the finance charge.
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#1225489 - 07/31/09 01:01 PM Re: Non-refundable application fee Skittles
pacar Offline
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Joined: Jul 2007
Posts: 320
Thanks, Duchess Skittles. I'm assuming that the issue of "refundable or not" will be in our state urusy laws? Or is there someplace in Reg Z where it outlines what is or is not refundable?
Last edited by pacar; 07/31/09 01:12 PM.
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#1225504 - 07/31/09 01:17 PM Re: Non-refundable application fee pacar
Skittles Online
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Skittles
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Posts: 13,963
TN
Actually it's up to your institution. An application fee, as long as it is charged to ALL applicants, is not considered a prepaid finance charge. This is listed in Reg Z - 226.4, I believe.
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#1225518 - 07/31/09 01:26 PM Re: Non-refundable application fee Skittles
pacar Offline
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Joined: Jul 2007
Posts: 320
Thank you!

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