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#1431277 - 08/19/10 02:31 PM filing fee - fed box
Tessie Offline
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Joined: Jan 2006
Posts: 155
If we are using a vehicle as collateral on a loan and we already have charged them to note lien, on a previous loan, are we suppose to put the charge in the filing fees in the fed box, even though we are not charging for a lien?

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Lending Compliance
#1433186 - 08/24/10 02:08 PM Re: filing fee - fed box Tessie
swiggles Offline
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swiggles
Joined: Aug 2001
Posts: 7,351
No.
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#1433298 - 08/24/10 03:40 PM Re: filing fee - fed box swiggles
Tessie Offline
100 Club
Joined: Jan 2006
Posts: 155
Thank you.
So where do you find the answer to questions like this?

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#1433328 - 08/24/10 03:56 PM Re: filing fee - fed box Tessie
swiggles Offline
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swiggles
Joined: Aug 2001
Posts: 7,351
Regulation Z...but not directly. Reg Z isn't like RESPA. You would never disclose a fee that you're not charging for the loan in question. You should read the Reg Z definition of a finance charge (226.4) and its commentary. Pay close attention to 226.4(e) regarding "certain security interest charges" and (a)'s reference to "comparable cash transactions."
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The more you sweat in training, the less you bleed in battle.......

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