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The branch manager compares the file facts with TILA HPML Rules during a borrower follow-up call. Which conclusion is accurate?

Correct Answer

B) Check escrow and appraisal duties for a covered HPML

HPML coverage depends on APR-over-APOR thresholds and carries escrow or appraisal duties. The best answer is "Check escrow and appraisal duties for a covered HPML".

Answer Options
A
Use an internal exception instead of the required federal disclosure or timing rule.
B
Check escrow and appraisal duties for a covered HPML
C
Use the ability-to-repay standard to decide the TILA HPML Rules issue before confirming the trigger facts.
D
Rely on oral agreement when the rule requires documented compliance.

Why This Is the Correct Answer

HPML coverage depends on APR-over-APOR thresholds and carries escrow or appraisal duties. The best answer is "Check escrow and appraisal duties for a covered HPML".

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