Attorney’s fees are excluded from the definition of “points and fees.” Is it correct to assume this exclusion would also include title company fees?
• Yes. The charges specifically excluded are fees for title examination, abstract of title, or similar purposes. If these services are not done by an attorney, then an assessment (closing agent charges) may be appropriate. Settlement charges are finance charges only if the creditor requires the service, requires the charge, or retains a portion of the third-party charge.
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