If there are security interest charges (filing fees) involved in a transaction that are required to perfect the bank’s security interest, they are a finance charge unless the fee(s) is (are) “itemized and disclosed” by the lender on/with the disclosure statement given to the borrower. The covered security interest charges are pretty broad, including any fees or taxes specified by relevant law to be paid to a government agency or premiums for insurance obtained in lieu of filing a lien (generally only in states where such insurance costs less than the governmental security interest changes). Whether the fee for the title itself is included would depend on your state’s process for issuing titles and notating liens. If a new title must be obtained to file the bank’s lien (with a fee for the title issuance), then the title fee would need to be included in the filing fees disclosure — unless the fee would be paid in a comparable cash transaction. This last criterion generally means that a title fee paid as part of an auto purchase transaction will not be included in the disclosed filing fee, while the same fee for a non-purchase transaction would have to be included in the “filing fee” disclosure. As you can see, how this process is handled in your state impacts what needs to be disclosed as “filing fees.” Flood Insurance. Q: Can the bank use a previous flood determination if it is not more than seven years old when we do an extension with no new money added to the loan? I read that you can rely on previous determination if the Federal Emergency Management Administration (FEMA) has made no map revisions or updates. Is there a way for the bank to check if revisions or updates have been done 100 South Phillips Avenue, Sioux Falls (605) 335-5112 | Teresa Thill advantage-network.com CONVENIENT, SECURE, AND FLEXIBLE DEBIT CARD PROGRAMS Whether it’s a business needing purchasing cards or an insurance card for medical expenses, we offer a variety of options to help you meet your customers’ needs. • Consumer and Business • Co-Branded and Affinity • Health Savings Accounts Visit our website to learn more about our debit card programs, or reach out to me and let’s start a conversation. NEBRASKA INDEPENDENT BANKER 11
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