HOEPA Worksheets
Louvera Walden started this HOEPA Worksheet and handed it off to David Dickinson of Bankers Compliance Consulting. David enhanced the HOEPA Worksheet and Andy Zavoina tweaked it to produce the HOEPA disclosure automatically. Bankers Compliance Consulting is now updating this on an annual basis.
Please note: Doc Prep Fees are only finance charges under Reg Z if retained by the lender, and some states won't allow anyone who is not an attorney to charge them. Even doc prep fees charged by an attorney, however, must be added into the fees and charges calculations in Georgia if the customer did not sign an affidavit of attorney selection. Customize, as needed, for your institution.
Pub. 12/29/10
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