[Claim for Real Estate Expenses]

An authorized certifying officer requested a decision on reclaim vouchers for the reimbursement of loan closing fees submitted by two employees. Both employees were transferred to new duty posts and claimed the loan closing fees in connection with the purchase of new residences. In both instances, the agency denied reimbursement of the claimed lump-sum fees, stating that absent itemization of allowable expenses the fees necessarily were regarded as nonreimbursable finance charges. The employees submitted letters from their respective banks stating that the fees were not a finance charge, and the agency asked GAO whether the bank's statements provided a basis for reimbursement of those fees. Regulations expressly categorize loan fees as finance charges when they are imposed incident to the extension of credit. GAO has held that a lump-sum fee for the processing or closing of a loan falls within the definition of a finance charge. Accordingly, the reclaim vouchers may not be certified for payment.