Is fee for home buyer education/counseling a prepaid finance charge?

I'm leaning toward "yes", if face-to-face, or its equivalent, is required by the lender, regardless of who provides the education, and "no", if face-to-face isn't required by the lender but the borrower obtains the education from a source that charges them a fee. Am I close?

I would concur with you, but I also know I have my secondary market investors who do not see it that way and mandate that it be included.

Thanks JJ. Anyone else?