In NYS, the cost of filing a UCC-1 has been increased significantly, so the bank wants to pass the charge onto the customer. The customer can pay the fee in cash, or add it to the loan amount.
What are the ramifications under REG Z? I believe this fee has to be disclosed to the customer in order for it NOT to be considered a finance charge. Is this correct?
Also, if it does have to be disclosed, I was planning on instructing everyone to disclose it in the FED Box under "Filing Fee". That way, it would be disclosed in a consistent manner, whether or not the fee was paid in cash, or added to the loan.