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#1240453 - 08/27/09 06:33 PM Reg Z questions
WHEDA Offline
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WHEDA
Joined: Apr 2009
Posts: 189
Wisconsin
When a home loan applicant is charged a fee for prepurchase home buyer counseling that is required by the lender/investor, is the cost of that counseling (that is paid to a HUD approved counseling agency selected by the applicant) considered a PPFC?

Thank you.

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Lending Compliance
#1240536 - 08/27/09 07:21 PM Re: Reg Z questions WHEDA
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
Yes. It's a fee being charged the applicant that is associated with the loan transaction and it's not an exempt fee under 226.4(c)(7).
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The opinions expressed are mine and they are not to be taken as legal advice.

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#1240545 - 08/27/09 07:28 PM Re: Reg Z questions Dan Persfull
WHEDA Offline
100 Club
WHEDA
Joined: Apr 2009
Posts: 189
Wisconsin
Thanks Dan. I wish I had half the knowledge base that you have!

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