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#2092859 - 08/11/16 09:54 PM include finance charges in MAPR
river girl Offline
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Joined: Nov 2004
Posts: 1,005
232.4(c)(1)(iii)(A)
include in MAPR calculation any finance charges associated with the consumer credit.

Am I safe to take the TIL Finance Charge Chart from the CFPB TILA exam manual and include any of those fees in the MAPR as well as the anciallary products, etc.

Just curious of the fees on the chart for now. IF the answer is yes, that means I include wire fees, fed ex fees, fee charged to LOC for overdraft transfers, auto title transfer fees, one time LOC origination fee.

Making sure I am understanding how to include "finance charges".

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#2093349 - 08/15/16 08:49 PM Re: include finance charges in MAPR river girl
river girl Offline
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Posts: 1,005
I am going to say yes...I would include all items from the finance charge chart in the calculation of the MAPR.

The Federal register states: In general, any charge that is a finance charge under REgulation Z, adopted by the Bureau, as well as certain other charges that would be covered as interest under 10 U.S.C. 987 (i)(3) must be included in the calculation of the MAPR.

(3)Interest.—
The term “interest” includes all cost elements associated with the extension of credit, including fees, service charges, renewal charges, credit insurance premiums, any ancillary product sold with any extension of credit to a servicemember or the servicemember’s dependent, as applicable, and any other charge or premium with respect to the extension of consumer credit.

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#2093357 - 08/15/16 09:22 PM Re: include finance charges in MAPR river girl
HRH Okie Banker Offline
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Oklahoma
But that won't include "title transfer" fees as mentioned by river girl would it? That's not a finance charge under Reg Z and I can't see it being a finance charge under MAPR. Anyone?
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#2093422 - 08/16/16 02:35 PM Re: include finance charges in MAPR HRH Okie Banker
Raquel Offline
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Joined: Aug 2007
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If a transaction has auto title transfer fees, wouldn't that be a purchase transaction which is exempt from MLA coverage?

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