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#1699360 - 05/14/12 08:44 PM Does this affect APR??
NegGhostrider Offline
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NegGhostrider
Joined: Mar 2011
Posts: 93
We have a loan where the title company is charging an "Electronic Document Delivery" fee. It is not listed on our APR chart and we are not sure if it affects our APR our not. Does anyone know?

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#1699375 - 05/14/12 09:16 PM Re: Does this affect APR?? NegGhostrider
RulesFollower Offline
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Are you requiring it? If you are, then yes it is included. That is how we decide on the items not directly listed on the APR chart.

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#1699378 - 05/14/12 09:22 PM Re: Does this affect APR?? NegGhostrider
NegGhostrider Offline
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NegGhostrider
Joined: Mar 2011
Posts: 93
It is not something that we require, but rather a fee that the title company had added to it. So by your reasoning, since it is not something that the bank requires then it would not affect the APR. Am I understanding that right?

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#1699404 - 05/15/12 01:59 AM Re: Does this affect APR?? NegGhostrider
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,617
Galveston, TX
(2) Special rule; closing agent charges. Fees charged by a third party that conducts the loan closing (such as a settlement agent, attorney, or escrow or title company) are finance charges only if the creditor:

(i) Requires the particular services for which the consumer is charged;

(ii) Requires the imposition of the charge; or

(iii) Retains a portion of the third-party charge, to the extent of the portion retained.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1699430 - 05/15/12 12:27 PM Re: Does this affect APR?? NegGhostrider
RR Joker Offline
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The Swamp
But consider this. If it's part of the title services, unless you are in a state that requires, or a loan program that requires, this fee should be part of the total in 1101 and not separately itemized.
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

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#1699476 - 05/15/12 01:28 PM Re: Does this affect APR?? NegGhostrider
NegGhostrider Offline
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NegGhostrider
Joined: Mar 2011
Posts: 93
Thank you all for your responses! I appreciate all of the help.

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