Re: Installment Loan Fees


Section 1026.4(c)(7) of Regulation Z states that filing fees may be excluded from the finance charge in transaction secured by real property or in a residential mortgage transaction, if the fees are bona fide and reasonable in amount.

Section 1026.4(d)(7) states that VSI premiums may be excluded from the finance charge if:
i. The insurer waives any right of subrogation.
ii. The other requirements of § 226.4(d)(2) are met. This includes, of course, giving the consumer the option of obtaining the insurance from a person of the consumer’s choice. The creditor need not ascertain whether the consumer is able to purchase the insurance from someone else.