Truth in Lending: 3.6.3.1 Charges Need Not Be Retained by the Creditor to Be “Imposed by the Creditor”
A charge must be “imposed directly or indirectly by the creditor” if it is to be considered a finance charge. This condition can cover a wide variety of charges, and the charge does not have to be retained by the creditor to have been imposed directly or indirectly by the creditor.