If either of the fees charged, the ERT fee or the “doc fee,” are considered finance charges, then it is likely that the dealer did not calculate the APR correctly. The ERT program fee is probably not a finance charge, as it is usually charged in comparable cash transactions. 12 CFR 1026.4(a)Comment 1, subsection (i)(A), Official Staff Commentary, 12 CFR 1026.4(a). However, the “doc” fee could be considered a finance charge if it reimburses the creditor for an expense that is incurred only in extending credit; you would have to contact the dealer and ask what the intent behind the fees was. Comment 1, Official Staff Commentary, 12 CFR 1026.4(a). (Note that the regulators had to specifically exempt document preparation fees from the scope of the term “finance charge” for residential real estate transactions. 12 CFR 1026.4(c)(7)(ii).)