We offer no closing costs on our helocs and fixed rate equities.

Since the borrowers do not pay any of the fees, are any of the costs still considered prepaid items?

I have totally confused myself and any help you can provide would be greatly appreciated!

A finance charge is an applicable charge paid by the borrower.

No problem for HELOCs, but if you offer the same "no closing costs" on your closed end home equities, you have to disclose all of the fees you as the lender incur on the GFE. They will be p.o.c. by lender, but still have to be disclosed.

We do disclose all of them p/o/c but I wasn't sure if they were considered a pre-paid finance charge (we were setting up an online application and the question came up...).

Thank you both for your help! Happy New Year!