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.

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.

All RESPA covered loans not just high or higher priced mortgages.

Thanks

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

Does the customer have to show prove of receiving counseling before closing of the loan?

Thanks

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.

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.

Thanks for your help.