In House Evaluation Fee - Finance Charge?

The Bank completed an in-house Evaulation on a real estate property securing a HELOC. Would this charge (which is similar to an appraisal fee) be considered a finance charge? I know appraisal fees are considered finance charges, but I wasn't sure about an in-house evaluation fee. Thanks.

Appraisal fees on real estate secured loans are not considered finance charges. Neither would your in-house evaluation fees. See 226.4(c)(7) and its Commentary.

I didn't read far enough into the reg. Thanks for clarifying Dan.

Along the same lines, you can't charge for an evaluation done by a bank employee, on a RESPA covered transaction, right? But its OK on an owner occupied construction, bridge or investment property... Am I thinking right?

RESPA does not prohibit you from a charging an in-house evaluation fee. You simply disclose it on the HUD the same as you would an appraisal fee.

I guess what I was thinking is that if you charge for it, you have to be able to document the cost of preparing it? Is that right or am I just losing it?