Disclosures for Funding HOEPA Credits?
by Dan Persfull, BOL Gurus Guru BIOS
Question: We currently have a customer who is a mortgage broker. He has a credit line with us which he uses to fund loans. As collateral, we took an assignment of those notes and trust deeds. He is interested in using a portion of his credit line to fund HOEPA related loans. Do we have any disclosure requirements?
Answer: No. However, I would make certain the broker is well versed in, and complies with HOEPA disclosures. If push came to shove, you may have difficulty exercising your assignment in the mortgage if the disclosures were not properly given.
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