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A team member asks about TILA Higher Priced Mortgage Loans in a daily pipeline review while trying to identify which rule controls the file. Which response should the file reviewer use?

Correct Answer

C) 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
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
Check escrow and appraisal duties for a covered HPML
D
Apply the correct general concept to the wrong asset documentation stage rather than the TILA Higher Priced Mortgage Loans rule.

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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