Answer:
No, however, if paid to an affiliate of the financial institution they would be part of the HOEPA charges if the loan is subject to HOEPA.
First published on BankersOnline.com 5/18/09
Real Estate Transaction Fees
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Question:
On real estate transactions, would fees such as title insurance that are normally not included in the APR need to be included in the APR prepaid finance charges if they are paid to a broker or a broker's affiliate and an affiliated business disclosure provided?
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