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#806977 - 08/31/07 02:30 PM TIL
J2C Offline
Diamond Poster
Joined: May 2004
Posts: 1,475
Big Brother knows and that's a...
In the training in May, the speaker said that Inspection fees on construction loans should be included in the Finance Chg calc. This seems wrong since we don't include appraisal fees, title ins, and other pass-through costs. Is this accurate??? Need answers ASAP.

Thanks!
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Lending Compliance
#806992 - 08/31/07 02:37 PM Re: TIL J2C
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
Definitely yes - see the commentary:

4(a) Definition.

1. Charges in comparable cash transactions. Charges imposed uniformly in cash and credit transactions are not finance charges. In determining whether an item is a finance charge, the creditor should compare the credit transaction in question with a similar cash transaction. A creditor financing the sale of property or services may compare charges with those payable in a similar cash transaction by the seller of the property or service.

ii. In contrast, the following items are finance charges:

A. Inspection and handling fees for the staged disbursement of construction loan proceeds.
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