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A borrower qualifies for a conventional loan at 4.5% interest and a government loan at 4.25% interest. Both loans have the same APR due to different fee structures. The MLO presents only the conventional loan because it generates higher compensation. This scenario represents:

Correct Answer

D) A steering violation since compensation influenced the loan selection

Under Regulation Z's anti-steering provisions, an MLO cannot steer a borrower away from a loan in a different category (conventional vs. government) based on compensation considerations, even if the APRs are the same. The MLO must present loans from each category for which the borrower qualifies.

Answer Options
A
Proper loan presentation since both loans have identical APRs
B
A violation because the government loan has a lower interest rate
C
Acceptable practice if the conventional loan has better terms overall
D
A steering violation since compensation influenced the loan selection

Why This Is the Correct Answer

Under Regulation Z's anti-steering provisions, an MLO cannot steer a borrower away from a loan in a different category (conventional vs. government) based on compensation considerations, even if the APRs are the same. The MLO must present loans from each category for which the borrower qualifies.

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