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#199085 - 06/10/04 05:41 PM HOEPA on a HELOC
Anonymous
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Does HOEPA apply to a HELOC that was used for a downpayment on a home. Our attorney stated that because it was an equity take out that HOEPA applied. I argued that HOEPA doesn't apply to purchase loans. Whose right?

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Lending Compliance
#199086 - 06/10/04 05:45 PM Re: HOEPA on a HELOC
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
You are. 226.32(a)(2)
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The opinions expressed are mine and they are not to be taken as legal advice.

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#199087 - 06/10/04 08:58 PM Re: HOEPA on a HELOC
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
FWIW, I agree with you and Dan.
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David Dickinson
http://www.bankerscompliance.com

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