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

Correct Answer

A) Compare APR to APOR as of the rate-set date

HPML coverage depends on APR-over-APOR thresholds and carries escrow or appraisal duties. The best answer is "Compare APR to APOR as of the rate-set date".

Answer Options
A
Compare APR to APOR as of the rate-set date
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
Delay the TILA HPML Escrow Requirements step until a later rate-lock 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 "Compare APR to APOR as of the rate-set date".

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