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A compliance exception review raises a TILA HPML Appraisal Rules question for a compliance analyst. What answer should guide the file?

Correct Answer

B) Apply HPML rules when APR exceeds the applicable APOR threshold

HPML coverage depends on APR-over-APOR thresholds and carries escrow or appraisal duties. The best answer is "Apply HPML rules when APR exceeds the applicable APOR threshold".

Answer Options
A
Use an internal exception instead of the required federal disclosure or timing rule.
B
Apply HPML rules when APR exceeds the applicable APOR threshold
C
Wait until a regulator asks for the file before applying the federal requirement.
D
Delay the TILA HPML Appraisal Rules step until a later closing disclosure review instead of acting now.

Why This Is the Correct Answer

HPML coverage depends on APR-over-APOR thresholds and carries escrow or appraisal duties. The best answer is "Apply HPML rules when APR exceeds the applicable APOR threshold".

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