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#2216182 - 06/20/19 08:41 PM MLA/Financing Loan Fee
NoJustNo Offline
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Joined: Oct 2013
Posts: 195
Midwest
If you finance an origination/loan fee on a vehicle purchase transaction, do you lose the purchase transaction exemption? I didn't think so but #2 from the Q&A gives me pause: https://s3.amazonaws.com/public-inspection.federalregister.gov/2017-26974.pdf

Quote:
Generally, financing costs related to the object securing the credit will not disqualify the transaction from the 4 exceptions, but financing credit-related costs will disqualify the transaction from the exceptions.

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#2216565 - 06/26/19 08:04 PM Re: MLA/Financing Loan Fee NoJustNo
NoJustNo Offline
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Joined: Oct 2013
Posts: 195
Midwest
Bump?

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#2216631 - 06/27/19 04:40 PM Re: MLA/Financing Loan Fee NoJustNo
Mountaineers_Fan Offline
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Joined: Jun 2018
Posts: 94
My understanding is that financing a fee like an origination/loan fee does cause the transaction to lose exemption. My understanding is that the quote you referenced is referencing credit ancillary products, such as GAP.

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#2217423 - 07/11/19 03:38 PM Re: MLA/Financing Loan Fee Mountaineers_Fan
NoJustNo Offline
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Joined: Oct 2013
Posts: 195
Midwest
That was my understanding, too - but I just can't seem to dig that out of the regulation?

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#2217748 - 07/16/19 05:06 PM Re: MLA/Financing Loan Fee NoJustNo
RR Joker Offline
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Joined: Nov 2002
Posts: 20,654
The Swamp
Agree
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