Community Bank Compliance
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Compliance Question of the Week
QUESTION: Does the fact that a bank employee or affiliate conducted the appraisal or inspection service impact the finance charge treatment of the related fee?
No, according to 1024.4(c)(7), the list of charges excluded as finance charges applies to both residential mortgage transactions and other transactions secured by real estate. This applies even if the services for which the fees are imposed are performed by the creditor’s employees instead of a third party.
Reference: 12 CFR 1026.4.