Skip to content
BOL Conferences
Thread Options
#2117116 - 02/06/17 05:04 PM Credit report and APR
mdog76 Offline
Platinum Poster
Joined: Jan 2007
Posts: 645
I'm sure this question has been asked before but does the credit report fee affect APR? Reading the definition of a finance charge is kind of confusing ha!

Thanks for the help

Return to Top
Lending Compliance
#2117120 - 02/06/17 05:10 PM Re: Credit report and APR mdog76
JC (Darth HMDA) Offline
Diamond Poster
JC (Darth HMDA)
Joined: Dec 2013
Posts: 1,399
CA
Is this for a RMT? If so, then no it should not be included:

§1026.4(c)(7)(iii)
2. The following fees in a transaction secured by real property or in a residential mortgage transaction, if the fees are bona fide and reasonable in amount:
iii. Notary and credit-report fees.


Yes... finance charge can definitely be confusing. smile
_________________________
The opinions expressed are mine, do not represent the opinions of my employer, and they are not to be taken as legal advice.

Return to Top
#2117122 - 02/06/17 05:14 PM Re: Credit report and APR mdog76
mdog76 Offline
Platinum Poster
Joined: Jan 2007
Posts: 645
Not for a particular transaction, just in general but I guess the transaction type matters.

Return to Top
#2117153 - 02/06/17 07:22 PM Re: Credit report and APR mdog76
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
As Darth provided the regulatory cite credit report fees are excluded from the finance charge for loans secured by real property or a residential mortgage transaction (RMT). A RMT is defined in Reg. Z 1026.2(a)(24).

A credit report fee for loans not secured by real property or a RMT would be a finance charge. See Reg. Z 1026.4(b)(4).
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

Return to Top
#2117186 - 02/06/17 09:07 PM Re: Credit report and APR mdog76
Richard Insley Offline
10K Club
Richard Insley
Joined: Oct 2000
Posts: 10,180
Toano, VA
Originally Posted By mdog76
just in general...
Reg. Z is loaded with exceptions to general rules. The applicable standard should be ascertained on a case by case basis.
_________________________
...gone fishing.

Return to Top

Moderator:  Andy_Z