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#2244495 - 10/22/20 09:04 PM MAPR Calculation Question
TeamComply Offline
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Joined: Aug 2016
Posts: 540
For MAPR Calculation purposes we are required to include "application fee" would this be the same thing as an "origination fee"?

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#2244498 - 10/22/20 09:59 PM Re: MAPR Calculation Question TeamComply
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Posts: 283
I am not sure if application fee and origination fee are synonymous, I would say that they are not. That said, finance charges are required to be included in the MAPR calculation and an origination fee is a finance charge.
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#2244896 - 10/30/20 06:40 PM Re: MAPR Calculation Question TeamComply
Andy_Z Offline
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The definitions of an application fee and an origination fee in my mind are different, but your definition can certainly vary. Regardless, the MAPR rules address this based on the plain language of the term, "application fee" and it's included:

https://www.bankersonline.com/regulations/32-232-004

232.4(c)(1)(iii)(B) Any application fee charged to a covered borrower who applies for consumer credit, other than an application fee charged by a Federal credit union or an insured depository institution when making a short-term, small amount loan, provided that the application fee is charged to the covered borrower not more than once in any rolling 12-month period; and
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#2292156 - 01/04/24 02:54 PM Re: MAPR Calculation Question TeamComply
Banker75 Offline
Member
Joined: Sep 2021
Posts: 99
For the MAPR, would you include GAP with credit insurance for the MAPR calculation? We don't get these loans very often and therefore I'm a little rusty. Trying to determine if this would be included like credit insurance or excluded under the reg.

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#2292233 - 01/07/24 01:50 PM Re: MAPR Calculation Question TeamComply
Andy Z Offline
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Joined: Feb 2013
Posts: 28
If you have a purchase money exception, no, because the loan is exempt. Otherwise yes, as it is an insurance item related to the transaction.

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#2292237 - 01/08/24 01:44 PM Re: MAPR Calculation Question TeamComply
Dan Persfull Offline
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Dan Persfull
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Posts: 47,529
Bloomington, IN
From the 4th circuit court - April 2023

https://www.consumerfinancemonitor....ith-vehicle-purchase-is-exempt-from-mla/

We don't sell GAP and we also do not do dealer financing so it's not something I've researched extensively. In fact since the implementation of the MLA we have only made 2 covered loans.
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The opinions expressed are mine and they are not to be taken as legal advice.

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