We have a $14 fee for a flood search on our applicable loans. Does anyone know if you need to include this in the points and fees test since it's not considered a finance charge? We've been using the Hoepa Worksheet here: http://www.bankersonline.com/tools/tools_lender.html#2a

We do not keep any of these proceeds and it's disclosed at application.
Just wondering what everyone else is doing.

We don't separate the initial determination cost from the life of loan cost so we treat the entire fee as a prepaid F/C.

If the $14 is for a one time determination, it is not included in the HOEPA fees test. If the $14 is partly for a life of loan determination, then you can either put the entire amount in the HOEPA fees test, or break out the life of loan portion and only include that portion in the fees test.

Isn't the fee included if the bank does its own flood certs and retains the fee.

Does the bank charge a life of loan fee? I haven't heard of banks doing this. The initial search is excludable much like a termite inspection fee. But if you paid for ongoing termite checks and treatments, that would be a FC just a s LOL is.

To clarify, the fee is just for the initital determination.