Upfront Fee on a HELOC

We charge an origination fee on a HELOC that all borrowers are required to pay upfront, out of pocket. It's not a finance charge and therefore not included in the APR calculation. Do we need to disclose this fee? I may be confusing closed-end/open-end on this holiday Monday.....

Without looking at the reg ( dangerous move), I thought an Application fee, charged to all Applicants was excluded, not origination fee to borrowers

Does it matter what you name it or when it's collected?

Fees accessed to the HELOC at account opening do not impact the APR. They would be disclosed on the initial disclosure. Yes, whether or not it is a finance charge will depend on what it is for and whether it is assessed to every single applicant.