would be $1691.78. The difference between the EAR and APR amounts to a difference of $64.09 per month. Over the life of a 30-year loan, this amounts to $23,070.86, which is over 11% of the original loan amount. Certain fees are not considered Some classes of fees are deliberately not included in the calculation of APR. Because these fees are not included, some consumer advocates claim that the APR does not represent the total cost of borrowing. Excluded fees may include: routine one-time fees which are paid to someone other than the lender (such as a real estate attorney's fee). penalties such as late fees or service reinstatement fees without regard for the size of the penalty or the likelihood that it will be imposed. Lenders argue that the real estate attorney's fee, for example, is a pass-through cost, not a cost of the lending. In effect, they are arguing that the attorney's fee is a separate transaction and not a part of the loan. Consumer advocates argue that this would be true if the customer is free to select which attorney is used. If the lender insists, however, on using a specific attorney, the cost should be looked at as a component of the total cost of doing business with that lender. This area is made more complicated by the practice of contingency fees – for example, when the lender receives money from the attorney and other agents to be the one used by the lender. Because of this, U.S. regulators require all lenders to produce an affiliated business disclosure form which shows the amounts paid between the lender and the appraisal firms, attorneys, etc. Lenders argue that including late fees and other conditional charges would require them to make assumptions about the consumer's behavior – assumptions which would bias the resulting calculation and create more confusion than clarity. Not a comparable standard Even beyond the non-included cost components listed above, regulators have been unable to completely define which one-time fees must be included and which excluded from the calculation. This leaves the lender with some discretion to determine which fees will be included (or not) in the calculation. Consumers can, of course, use the nominal interest rate and any costs on the loan (or savings account) and compute the APR themselves, for instance using one of the calculators on the internet. In the example of a mortgage loan,