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#2155243 - 11/29/17 02:30 PM Itemizing/Charging Credit Report Fees (MLA, etc.)
NoJustNo Offline
100 Club
Joined: Oct 2013
Posts: 221
Midwest
Do you include all of the following fees as "credit report" fee on the LE/CD? FactualID, OFAC Extended Search, MLA Search?

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Lending Compliance
#2155408 - 11/29/17 09:48 PM Re: Itemizing/Charging Credit Report Fees (MLA, etc.) NoJustNo
awilli Offline
Gold Star
Joined: Oct 2014
Posts: 291
We just disclose the credit report fee as credit report fee. We pull through Equifax, so all the charges entailed with Equifax is the total charge we disclose on the LE. I believe we just use a standard average. Like a flat $2.50 per pull.
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#2155416 - 11/29/17 10:05 PM Re: Itemizing/Charging Credit Report Fees (MLA, etc.) NoJustNo
NoJustNo Offline
100 Club
Joined: Oct 2013
Posts: 221
Midwest
Thoughts on if including the MLA search or the Factual ID would cause issues with not considering the fee a finance charge? It seems to me like those charges wouldn't qualify as a "credit report."

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