Is a transfer fee charged to a checking account when a transfer is made to the account from a LOC considered a finance charge on the loan side? We disclose the fee in our TIS disclosure.

Check out the OSC to 226.4(b)(2). My reading of this is that it would be a finance charge to the extent that it exceeds a fee if a credit product is not attached. For example, if you charge an overdraft or NSF fee, the transfer fee would be a finance charge to the extent it would exceed an overdraft or NSF fee (if it would exceed the OD or NSF fee).

Thank you. That is how a read it, but have a loan officer questioning it.