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apr fee

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  • July 10, 2015 at 2:51 pm EDT #7143
    mdunker
    Member

    We are going to be charging a tax service fee to our customers, I am trying to figure out if this is an APR fee or not. I beleive that it is since it is a life of loan fee. Would it also be an APR fee for Hom Equity Lone Of Credit Loans?

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  • July 13, 2015 at 10:43 pm EDT #7147
    rcooper
    Member

    I agree that the tax service fee would be included in the APR for closed-end credit. For HELOCs look to 1026.14(c) and its commentary. Also consider 1026.7(a)(6).

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