Jack,
I think I’m now confused even more. 99% of our installment loans disclose both the VSI and filing fees on the TIL (generally because they are part of the amount financed). On occasion these fees are paid in cash and have not been included in the TIL calculation, nor in the itemization of amount financed.
Are they now prepaid finance charges? Sorry for the elementary questions, but I’m fairly new at this.