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A file carries a $1,900 origination fee, $640 of prepaid interest, a $525 appraisal the borrower paid for, $1,100 of owner title insurance she chose, and $95 for a credit report.

Correct Answer

C) The $1,900, the $640 and the $95 are finance charges; the other 2 are not

A finance charge is what the consumer pays as an incident of the credit and would not pay in a comparable cash transaction, which catches the origination fee, the prepaid interest and the credit report. An appraisal and owner title insurance are excluded. Other choices: sweeping in all five ignores the exclusions the section sets out; treating only the origination fee as a finance charge drops two that plainly qualify; and picking the appraisal and the owner policy names the two that are excluded. Source: 12 CFR 1026.4(a) and (c)

Answer Options
A
The $1,900, the $525 and the $1,100 are finance charges; the other 2 are not
B
Only the $1,900 is a finance charge; the other 4 are third-party costs
C
The $1,900, the $640 and the $95 are finance charges; the other 2 are not
D
All 5 are finance charges, since each is paid to obtain the credit

Why This Is the Correct Answer

A finance charge is what the consumer pays as an incident of the credit and would not pay in a comparable cash transaction, which catches the origination fee, the prepaid interest and the credit report. An appraisal and owner title insurance are excluded. Other choices: sweeping in all five ignores the exclusions the section sets out; treating only the origination fee as a finance charge drops two that plainly qualify; and picking the appraisal and the owner policy names the two that are excluded. Source: 12 CFR 1026.4(a) and (c)

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