I have researched these two (somewhat) related questions regarding e-filing/e-recording mortgages and could find some threads, but they were from 2015, so I hope no one cares that I ask again, as I am looking for current thoughts. Everyone's help on here is always so much appreciated.

When I say E-file fee, I am referring to the fee to actually e-file or e-record a mortgage. In this circumstance in WI, recording a mortgage is $30. We we will be paying $4 to a third party to have them e-record or e-file for us, so the total would be $34.


1) E-file fee - is it a finance charge? On a HELOC would it need to be disclosed on the first periodic statement if yes (I would think so if a finance charge). If yes, so you are itemizing it by itself?
2) Where on the LE does this go. I saw people saying that they would put the $4 fee in section B. The people I asked locally in WI were wrapping it into the origination charge. This does not appear to be a state specific question, so wondering where people are putting it?

THANKS!

1. Yes, it is a F/C. It would appear on the first HELOC statement if it was paid out of the line.

1026.7(a)(6)(i) Comment 8. Start-up fees. Points, loan fees, and similar finance charges relating to the opening of the account that are paid prior to the issuance of the first periodic statement need not be disclosed on the periodic statement. If, however, these charges are financed as part of the plan, including charges that are paid out of the first advance, the charges must be disclosed as part of the finance charge on the first periodic statement. However, they need not be factored into the annual percentage rate. (See § 1026.14(c)(3).)

2. It would go in Section B or C, as applicable.

As usual, your help is so very much appreciated. It is really nice to be able to get this kind of help when needed. Thank You!!!