According to Z, the flood determination fee is not a finance charge. It is when I read the commentary that I get confused, specifically: If a creditor is uncertain about what portion of a fee to be paid at consummation or loan closing is related to the initial decision to grant credit, the entire fee may be treated as a finance charge.
So is it acceptable to lump the determination & life of loan fees & treat both as a finance charge or not?
I have one area treating life of loan as a finance charge
& another disclosing both the determination & life of loan as finance charge
.