Is the Life of Loan Fee always a part of the finance charge?

Is the Flood Determination Fee not included in the finance charge if it is bona fide and reasonable?

Is there a simple way to remember this!?!?

Yes
Yes
and Yes - Any charge for a service that happens loan after closing (i.e. life of loan coverage) is a finance charge.

3. Charges assessed during the loan term. Real estate or residential mortgage transaction charges excluded under §1026.4(c)(7) are those charges imposed solely in connection with the initial decision to grant credit. This would include, for example, a fee to search for tax liens on the property or to determine if flood insurance is required. The exclusion does not apply to fees for services to be performed periodically during the loan term, regardless of when the fee is collected. For example, a fee for one or more determinations during the loan term of the current tax-lien status or flood-insurance requirements is a finance charge, regardless of whether the fee is imposed at closing, or when the service is performed. If a creditor is uncertain about what portion of a fee to be paid at consummation or loan closing is related to the initial decision to grant credit, the entire fee may be treated as a finance charge.

Thank you, Mr. Carey.