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Re: Truth In Lending

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#2921
JGo9
Participant

1026.2 Definitions and rules of construction

(23) Prepaid finance charge means any finance charge paid separately in cash or by check before or at consummation of a transaction, or withheld from the proceeds of the credit at any time.

Above is the definition of Prepaid Finance Charges as defined in Reg Z. The terms you mentioned are not specifically defined in Reg Z so I’ll have to interpret them.

If a fee fits the definition of a “Prepaid Finance Charge” and is include in the loan amount then to me that would be a “financed prepaid financed charge”. Any fees that do not fit the definition of a Prepaid Finance Charge that is then included in the loan amount aka financed, then to me that would be “other charges financed”.

Hope this helps!