We believe that a document preparation fee would be considered a finance charge, as it would not be charged in a comparable cash transaction and does not fall into any of the categories that are exempted from the definition of a finance charge. 12 CFR 1026.4(a). Of course, document preparation fees charged in a real estate transaction have a special exemption from the definition of finance charge, but that exception does not apply to non-real-estate transactions. 12 CFR 1026.4(c)(7)(ii). And, the fact that the rule’s drafters saw it necessary to specifically exempt doc prep fees for real estate transactions lends weight to the conclusion that generally, such fees are considered part of the finance charge.