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#2242592 - 09/16/20 11:05 PM .18(o) Certain Security Interest Charges & Fed Box
NoJustNo Offline
100 Club
Joined: Oct 2013
Posts: 188
Midwest
What is 1026.18(o) getting at? That the security interest charges need to be in the fed box on consumer loans -- or is it sufficient to separately itemize them? The way it's worded + the commentary doesn't seem to me that it's required to be *in* the fed box -- but I've never been clear why so many TILA boxes had the security interest charges inside the fed box. Can anyone enlighten me?

(o) Certain security interest charges. The disclosures required by § 1026.4(e) in order to exclude from the finance charge certain fees prescribed by law or certain premiums for insurance in lieu of perfecting a security interest.

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Lending Compliance
#2242596 - 09/17/20 11:36 AM Re: .18(o) Certain Security Interest Charges & Fed Box NoJustNo
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 77,215
Galveston, TX
There is no requirement that the .18(o) disclosure be segregated into the Fed Box, but most loan doc prep systems do.

Official Interpretation

18(o) Certain Security Interest Charges

1. Format. No special format is required for these disclosures; under §1026.4(e), taxes and fees paid to government officials with respect to a security interest may be aggregated, or may be broken down by individual charge. For example, the disclosure could be labeled “filing fees and taxes” and all funds disbursed for such purposes may be aggregated in a single disclosure. This disclosure may appear, at the creditor's option, apart from the other required disclosures. The inclusion of this information on a statement required under the Real Estate Settlement Procedures Act is sufficient disclosure for purposes of Truth in Lending.
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