Skip to content

Document Review Fee a Finance Charge?

Question: 
A simple question that may be obvious: We know that "document preparation" fees are not finance charges under 226.4(c)(7), but what about a "document review" fee?
Answer: 

Answer by Andy Zavoina: I would consider this a cost of the loan and not exempted, as you have already passed along a charge for preparing this document. I do not see this conclusively in the regulation, but rather this is a gut reaction based on the spirit and intent of the rules.

Answer: 

Answer by Dan Persfull: I agree with Andy. Your document preparation fee is to cover the cost of getting the documents ready for closing. Wouldn't reviewing the documents be part of that preparation?

First published on BankersOnline.com 4/4/05

First published on 04/04/2005

Filed under: 
Filed under lending as: 

Search Topics