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#1083822 - 11/19/08 01:28 AM HOEPA
carpenter Offline
Member
Joined: Sep 2006
Posts: 90
Is a loan subject to HOEPA if its a Refi on a non-owner occupied dwelling but is cross collaterized with the primary residence?

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Lending Compliance
#1083923 - 11/19/08 01:33 PM Re: HOEPA carpenter
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
It depends on the loan's purpose. If the loan meets the business purpose exemption then it would not be subject to the provisions of Reg. Z. If it's a consumer purpose loan then Reg Z and the HOEPA section would apply.
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The opinions expressed are mine and they are not to be taken as legal advice.

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