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#474099 - 12/22/05 07:31 PM Is it a Finance charge?
lvm Offline
100 Club
Joined: Mar 2005
Posts: 200
I see on the wholesale files, the broker charges admin fee, processing fee, Fed ex, messenger fees, etc. I know the broker points are finance charge eventhough the brokers are not required to be used. How about the other fees mentioned above? It seems to me they are FC but need confirmation. Thanks for your help.

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Lending Compliance
#474100 - 12/22/05 07:41 PM Re: Is it a Finance charge?
GreatBlue Offline
Diamond Poster
GreatBlue
Joined: Feb 2003
Posts: 2,362
Colorado
Yes, generally any fee the mortgage broker charges (regardless of what it is called) is considered a prepaid finance charge unless it is the type of fee that is also excluded when charged by the lender (e.g. appraisal fees).
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#474101 - 12/22/05 07:56 PM Re: Is it a Finance charge?
lvm Offline
100 Club
Joined: Mar 2005
Posts: 200
Thank you GreatBlue.

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#474102 - 12/24/05 02:06 PM Re: Is it a Finance charge?
Rocky P Offline
Power Poster
Joined: Jun 2003
Posts: 7,399
Florida
lvm - GB is right on - there is one other side issue.

If you're testing for high cost loans, you may want to check state regulations too. Depending on the state, there may be some fees which are not considered prepaid finance charges however which would need to be included in calculating high cost loans (per the state predatory lending laws).
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