Kirchman has distributed an advisory called "Beware...A New Interpretation of Finance Charges Under Regulation Z." Sorry I don't know how to created a link, but you can find it at www.kirchman.com/comply
under Hot Issues. If I read this correctly, wouldn't all mortgage loans be vulnerable to this "new"violaton? We do a final title searche on all mortgages post-closing. In addition, our FDIC exmaminers have always forced us to add the last "inspection" fee on a construction loan into the appraisal fee. For example, if there were 6 inspections during construction, only 5 could be in the Finance Charge, otherwise we'd be written up for over-disclosing the FC. Based on this Kirchman advisory, this would confirm our feeling that the last post-closing inspection fee shouldn't be in the appraisal at all. The article says that FDIC is noting this violation in 40% of banks. I don't know what a "survey" fee is, but has anyone see this interpretation applied to the "inspection fees?.