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#2244495 - 10/22/20 09:04 PM MAPR Calculation Question
TeamComply Offline
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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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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.
Opinions expressed are my own and do not reflect legal advice or the opinions of my employer.

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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:

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
My opinions are not necessarily my employers.
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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