Answer:
Yes, however it will be a finance charge for Reg Z purposes.
First published on BankersOnline.com 12/17/07
Passing the Fee to the Borrower
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Question:
In order to comply with the Patriot Act, our company orders a separate report to determine the validity of a potential customer's DOB, SSN, name and address. Since this is a separate report from the credit report, are we allowed to pass the fee onto the borrower?
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