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Before the team acts on a production meeting, a risk reviewer must address HOEPA Points and Fees. Which response is most defensible?

Correct Answer

C) Test the loan against HOEPA high-cost triggers

HOEPA/high-cost mortgage rules use rate, points-and-fees, and prepayment-penalty triggers and restrict risky terms. The best answer is "Test the loan against HOEPA high-cost triggers".

Answer Options
A
Use an internal exception instead of the required federal disclosure or timing rule.
B
Use prior advertising disclosure approval as a substitute for the current HOEPA Points and Fees requirement.
C
Test the loan against HOEPA high-cost triggers
D
Rely on oral agreement when the rule requires documented compliance.

Why This Is the Correct Answer

HOEPA/high-cost mortgage rules use rate, points-and-fees, and prepayment-penalty triggers and restrict risky terms. The best answer is "Test the loan against HOEPA high-cost triggers".

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