MLA/Financing Loan Fee

Posted By: NoJustNo

MLA/Financing Loan Fee - 06/20/19 08:41 PM

If you finance an origination/loan fee on a vehicle purchase transaction, do you lose the purchase transaction exemption? I didn't think so but #2 from the Q&A gives me pause: https://s3.amazonaws.com/public-inspection.federalregister.gov/2017-26974.pdf

Quote:
Generally, financing costs related to the object securing the credit will not disqualify the transaction from the 4 exceptions, but financing credit-related costs will disqualify the transaction from the exceptions.
Posted By: NoJustNo

Re: MLA/Financing Loan Fee - 06/26/19 08:04 PM

Bump?
Posted By: Mountaineers_Fan

Re: MLA/Financing Loan Fee - 06/27/19 04:40 PM

My understanding is that financing a fee like an origination/loan fee does cause the transaction to lose exemption. My understanding is that the quote you referenced is referencing credit ancillary products, such as GAP.
Posted By: NoJustNo

Re: MLA/Financing Loan Fee - 07/11/19 03:38 PM

That was my understanding, too - but I just can't seem to dig that out of the regulation?
Posted By: RR Joker

Re: MLA/Financing Loan Fee - 07/16/19 05:06 PM

Agree