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HOEPA Worksheets
Updated 12-21-07.
Louvera Walden started this HOEPA Worksheet, plus, a second worksheet that states when the Georgia Fair Lending Act or HOEPA law applies. David Dickinson of Bankers Compliance Consulting enhanced the HOEPA Worksheet and Andy Zavoina tweaked it to produce the HOEPA disclosure automatically. David recently updated to 2007 specifications, which is linked below.
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.
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