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Before the team acts on a supervisory file review, a processor must address TILA Higher Priced Mortgage Loans. Which response is most defensible?

Correct Answer

A) Use the subordinate-lien threshold when the loan is junior-lien

HPML coverage depends on APR-over-APOR thresholds and carries escrow or appraisal duties. The best answer is "Use the subordinate-lien threshold when the loan is junior-lien".

Answer Options
A
Use the subordinate-lien threshold when the loan is junior-lien
B
Use prior credit underwriting approval as a substitute for the current TILA Higher Priced Mortgage Loans requirement.
C
Wait until a regulator asks for the file before applying the federal requirement.
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 "Use the subordinate-lien threshold when the loan is junior-lien".

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