On a closed-end subordinate lien home improvement loan (fixed amount, rate & term, & single disbursement) where costs (credit report, title search, recording fees, flood plain determination) are paid from loan proceeds, and some of those costs are considered a PPFC (recording fee for Assignment to investor, post-closing inspection & life-of-loan flood cert coverage), is the APR calc based on the gross Note amount or net of the costs paid from loan proceeds?
Thank you for your help.