Answer by David Dickinson: If the fee is earned AFTER closing, it is a prepaid finance charge (PPFC). If the fee is for services BEFORE closing, it is not. For instance, a flood determination is not a finance charge, but the life-of-loan monitoring is a PPFC.
When is the service performed for the inspection? If before closing, it is not a PPFC. If the inspection is after closing, it is a PPFC.
Answer by Dan Persfull: No.
First published on BankersOnline.com 3/7/05