I tend to add the filter factor after metering the scene. however, this is one of those questions that will create opposite answers.
I found that the built-in meters in my Nikons see color-filtered light differently than film.
Black and White Filtering Notes ( Nikon EL2 + 55/1.2 AI Nikkor, ASA 100 sunlight, gray card)
This is in the form: Filter, Δf, Δf meter
Hoya K2 (8) yellow, 1, 0
Hoya O(G) orange, 2, 0.6
Vivitar 25A red, 3, 1.6
Hoya X(0) yellow-green, 1.5, 0.5
Hoya X(1), 2, 1.6
The through-the-filter readings are too high in each case. The error varies with the filter color.
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If the meter cell has any colour sensitivity (or insensitivity) it will bias the reading. If the subject has a dominant colour that matches the filter it will inflate the reading, possibly leading to an underexposure (or vice versa). And this assumes that the film sensitivity is normal panchromatic. Filter factors should give a consistent exposure correction. Ideally you should compare the results of a filter factor exposure with a through the filter measurement and make your own corrections for the meter behaviour if needed.
If you hold a filter in front of a meter you may be adding flare to the equation as well.
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