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#2200381 - 12/11/18 09:05 PM PEL Approval Disclosure Amt Pd to Others
Likes to Comply Offline
Diamond Poster
Joined: Nov 2008
Posts: 1,062
In the mountains
We have a PEL secured by a motor vehicle. Would fees such as Non-RE filing fees (security filing) and SII be listed on the Private Education Loan Approval and Final disclosure under "Amount paid to others on your behalf" or under "Fees" or not at all?

1026.47(b)(2)(i) - an itemization of the fees or range of fees to obtain the private education loan; Official Interpretation 47(b)(2)-1 refers to 1026.47(a)(2) and also states "if the creditor includes the itemization of amount financed under 1026.18(c)(1), any fees disclosed as part of the itemization need not be separately disclosed elsewhere.. Official Interpretation 47(a)(2)-2 says fees disclosed includes all finance charges under 1026.4, fees not considered finance charges but required to obtain credit, and those paid by the consumer directly to the creditor and fees paid to third parties by the creditor on the consumer's behalf.

The model notices only show under "Fees" - late charges, returned check charge and fee when you begin repaying the loan. Under "Amount paid to others on your behalf" it shows a payment to a university.

Thanks in advance.
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Lending Compliance
#2200573 - 12/13/18 01:40 PM Re: PEL Approval Disclosure Amt Pd to Others Likes to Comply
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,931
Galveston, TX
Both Models H-22 & 23 have the itemization of amount financed box as required by .18(c)(1). I am not sure why that itemization would be any different than one you would provide on just a car loan where the proceeds would not be used for education. Refer to model H-3.
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