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During a borrower intake review, the loan team encounters a HOEPA Points and Fees issue. Which response should resolve the issue before the file moves forward?

Correct Answer

D) Provide required counseling and disclosures when HOEPA applies

HOEPA/high-cost mortgage rules use rate, points-and-fees, and prepayment-penalty triggers and restrict risky terms. The best answer is "Provide required counseling and disclosures when HOEPA applies".

Answer Options
A
Use an internal exception instead of the required federal disclosure or timing rule.
B
Wait until a regulator asks for the file before applying the federal requirement.
C
Apply the correct general concept to the wrong fee tolerance stage rather than the HOEPA Points and Fees rule.
D
Provide required counseling and disclosures when HOEPA applies

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 "Provide required counseling and disclosures when HOEPA applies".

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