We are in the process of implementing a NO CLOSING COST loan program. We will, in fact, pay all fees except accrued interest. The GFE reflects all fees in connection with the loan as POC. Could we still advertise NO CLOSING COSTS if the borrower is required to pay only the accrued interest?

Thank you.

Yes.

I would like to tag in on this conversation. We are planning a HELOC promotion. We plan to advertise this as a "No Closing Costs". We do indicate in our Terms and Conditions that if the loan is paid off during the first 3 years, the borrower is responsible for paying back 3rd party fees such as Drive By Appraisal, Title Abstract, Flood Search, Annual Tax Service, etc., etc..

Under the Reg. can we advertise this as "No Closing Costs"?