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#2163782 - 02/08/18 10:42 PM Subject to Reg Z?
Bville Offline
Diamond Poster
Bville
Joined: May 2001
Posts: 1,282
Out West
One of the requirements for a loan to be subject to Reg Z is:

(iii) The credit is subject to a finance charge or is payable by a written agreement in more than four installments;

Does this mean any charge that fits into Reg Z's definition of finance charge, or does it mean the borrower has to pay interest? I came across a loan (for down payment assistance) that charges no interest, and has no monthly payments (just a single payment), but it was charged an origination fee. Will the origination charge fit the requirement above?

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Lending Compliance
#2163786 - 02/08/18 11:08 PM Re: Subject to Reg Z? Bville
Richard Insley Offline
10K Club
Richard Insley
Joined: Oct 2000
Posts: 10,180
Toano, VA
Yes.
_________________________
...gone fishing.

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