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Before the team acts on a supervisory file review, the supervisor must address TILA HPML Restrictions. Which response is most defensible?

Correct Answer

A) 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
Check escrow and appraisal duties for a covered HPML
B
Use an internal exception instead of the required federal disclosure or timing rule.
C
Wait until a regulator asks for the file before applying the federal requirement.
D
Use prior SAFE Act testing approval as a substitute for the current TILA HPML Restrictions requirement.

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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