How are other Illinois banks diclosing the title filing fee when financing the purchase of a vehicle? While Reg. Z states that to omit security interest filing fees from the finance charge the bank must disclose (usually in the fed box). Since Illinois does not have a specific fee to perfect a security interest for a vehicle title, is this disclosure necessary. Really looking to see how examiners are addressing this issue. i have heard some want it in the security interest filing fee line in the fed box and others don't care. Any thoughts or comments?

For auto purchases, the dealership collects and processes the title fee. For private party purchases, sales tax is paid separately thru the Secy of State office or currency exchange when registering the vehicle. We only collect the title fee of $65 (outside of the loan)when financing the refinance of a used vehicle from another FI so we can record a new lien.

So does your bank show the $65 title fee on the filing fee line within the fed box of the truth in lending disclosure statement? This is the area of confusion on whether it should be shown or not. The regulation says to exlude from finance charge security interest filing fees need to be disclosed to the consumer. The question is whether the title fee in Illinois is really a filing fee to perfect a security interest or lien.

We don't list - they are so far and few between, but it is to perfect a lien, but I guess it could also be considered simply a corrected title, since that is the name on the document sent to the State.