Is the Closing Protection Coverage charge considered a Pre-paid finance charge? The CPC is the new state of OH coverage required to be offered when title insurance is provided; title coverage can be offered in a cash transaction, as well as a loan transaction. As a lender, we always request the coverage for us as the lender-cost-$35.00.

Same questions, but pertaining to a charge from the title agent for packaging the documents-printing our closing documents from the web site; or a charge for our incoming wire; or, an outgoing wire fee from the title company to the seller, or to wire payoff funds.

When in doubt, I would include the charge a prepaid. I would think you could make an argument for exclusion under 226.4(c)7, however, if done through an affiliate - you may have include under high cost testing. What line on the HUD are you disclosing the fee? Under 1109?

The closing protection fee does appear to be a finance charge -- whether a "prepaid" FC or not depends on when paid. Since it is paid at/before closing or withheld from proceeds, it is a prepaid FC.

The title agent's doc prep/packaging fee may be excludable. You need to take a close look at the Official Staff Commentary for Reg Z, section 226.4(c)(7), to see if what they are doing for the fee falls in the excludable category.

Wire fees should probably be considered finance charges, definitely one transmitting a payoff. The fee for the wire to the seller may (should?) be paid by the seller, which would exclude it from the buyer's/borrower's finance charge.