Since the origination charge would be a FC and the in-house is not, it's separated for APR calculation, but it would need to be subtracted to get the TLA since it's not a FC.
I believe you are correct, Always. This matches up with a prior thread where it was broken down nicely (I think dblack did the breakdown)
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My opinion only. Not legal advice.
Say you'll haunt me - Stone Sour