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#1897650 - 02/15/14 04:07 PM HO COUNSELING NOTICE
theloanbug Offline
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Joined: Sep 2005
Posts: 720
Let me make sure I undertand this correctly. We only give the disclosure and the list if t is a HOEPA Loan?

Thank you for your help.

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HOEPA and Homeowner Counseling Rule
#1897657 - 02/15/14 05:37 PM Re: HO COUNSELING NOTICE theloanbug
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,637
Galveston, TX
No, it is not a Reg. Z requirement to provide the disclosure and the list. It is a RESPA requirement. All RESPA covered loans except reverse mortgage and timeshares plans get it. See 1024.20.
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#1897883 - 02/18/14 06:22 PM Re: HO COUNSELING NOTICE theloanbug
theloanbug Offline
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Joined: Sep 2005
Posts: 720
All RESPA covered loans not just high or higher priced mortgages.

Thanks

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#1897894 - 02/18/14 06:47 PM Re: HO COUNSELING NOTICE theloanbug
Ishmael Offline
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Joined: Feb 2011
Posts: 232
Pequod
The rule applies to high-cost and non high-cost loans alike. See 1024.20 or p. 33 of this guide:

http://files.consumerfinance.gov/f/201401_cfpb_hoepa-compliance-guide.pdf

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#1898372 - 02/20/14 01:13 AM Re: HO COUNSELING NOTICE Ishmael
theloanbug Offline
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Joined: Sep 2005
Posts: 720
Does the customer have to show prove of receiving counseling before closing of the loan?

Thanks

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#1898396 - 02/20/14 02:03 PM Re: HO COUNSELING NOTICE theloanbug
dblack Offline
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Joined: Feb 2008
Posts: 263
AL
For most loans they don't actually have to have the counseling.

HCML loans need counseling and I believe some form of first time buyers do as well, but I don't have the cite with me at the moment to confirm.
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#1898398 - 02/20/14 02:05 PM Re: HO COUNSELING NOTICE theloanbug
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,684
Cape Cod
Under Reg Z, there is a requirement for pre-consummation counseling for first-time borrowers if the loan periodic payments could result in negative amortization. Also for HCMLs.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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#1898404 - 02/20/14 02:19 PM Re: HO COUNSELING NOTICE John Burnett
theloanbug Offline
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Joined: Sep 2005
Posts: 720
Thanks for your help.

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