In the past, we have considered both satisfaction and recording fees as finance charges. After reading the Reg more closely, we have decided NOT to count them as PPFCs:
Reg Z 226.4(e)(1)
(e) Certain security interest charges. If itemized and disclosed, the following charges may be excluded from the finance charge:
(1) Taxes and fees prescribed by law that actually are or will be paid to public officials for determining the existence of or for perfecting, releasing, or satisfying a security interest.