I know the term PFC doesn't show up in Subpart B, but it does in the General terms of Subpart A - specifically 226.4 on Finance Charges. Section 226.3 Exempt Transactions specifically says anything secured by real estate is not exempt but doesn't seem to differentiate between open end RE or closed end RE and that's what is getting me confused.
(b) Credit over $25,000 not secured by real property or a dwelling. An extension of credit in which the amount financed exceeds $25,000 or in which there is an express written commitment to extend credit in excess of $25,000, unless the extension of credit is:
(1) Secured by real property, or by personal property used or expected to be used as the principal dwelling of the consumer; or
We will leave all the fees as NOT prepaid finance charges for the closing. Thanks for answering so quickly!!
"There should be a critical duration time after which it is perfectly acceptable to bite someone like a raptor." D. Shepherd