I'm no expert, but FWIW, I agree that it is a finance charge. I'm looking in the commentary at 226.4(e)(1)(ii). How do you interpret "If the obligation is between the creditor and a third party..."?
This position is echoed by one of our secondary market sources, and they've stated that they expect a subordination fee AND a subordination recording fee to be included in the f/c calculation in order for them to purchase the loan.
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