An origination fee is considered a finance charge under TILA because it represents the cost of obtaining credit. A finance charge includes all fees that a borrower must pay as a condition of securing a loan, excluding certain exempt fees like notary or appraisal fees.
* Notary fees (A) and appraisal fees (C) are typically excluded from the finance charge calculation.
* Late payment fees (D) are not considered finance charges; they are penalties for delinquent payments.
References:
* Truth in Lending Act (TILA), 12 CFR §1026.4 (Regulation Z)
* CFPB Finance Charge Definitions