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#2201429 - 12/24/18 07:37 PM Upfront Fee on a HELOC
Mel in WA Offline
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Joined: Mar 2013
Posts: 1,175
We charge an origination fee on a HELOC that all borrowers are required to pay upfront, out of pocket. It's not a finance charge and therefore not included in the APR calculation. Do we need to disclose this fee? I may be confusing closed-end/open-end on this holiday Monday.....

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#2201430 - 12/24/18 07:47 PM Re: Upfront Fee on a HELOC Mel in WA
Rocky P Offline
Power Poster
Joined: Jun 2003
Posts: 7,402
Florida
Without looking at the reg ( dangerous move), I thought an Application fee, charged to all Applicants was excluded, not origination fee to borrowers
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#2201431 - 12/24/18 09:00 PM Re: Upfront Fee on a HELOC Mel in WA
Mel in WA Offline
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Joined: Mar 2013
Posts: 1,175
Does it matter what you name it or when it's collected?

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#2201433 - 12/24/18 09:19 PM Re: Upfront Fee on a HELOC Mel in WA
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,352
Galveston, TX
Fees accessed to the HELOC at account opening do not impact the APR. They would be disclosed on the initial disclosure. Yes, whether or not it is a finance charge will depend on what it is for and whether it is assessed to every single applicant.
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