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BankersOnline.com Forums Dodd-Frank Final Rules Discussions HOEPA and Homeowner Counseling Rule Anti-Predatory Lending Policy
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#2132908 - 06/02/17 04:24 PM Anti-Predatory Lending Policy
Reg Warrior Online
100 Club
Joined: Jan 2017
Posts: 214
My board is looking to consolidate policies. They would like to eliminate the Anti-Predatory Lending Policy and incorporate it with the Fair Lending Policy. Does anyone know if there is a requirement to have a separate Anti-Predatory policy? Is incorporating into the Fair Lending policy a good idea, or should in be in a TILA related policy?

Thanks

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HOEPA and Homeowner Counseling Rule
#2132915 - 06/02/17 04:37 PM Re: Anti-Predatory Lending Policy Reg Warrior
MScarn6942 Offline
Platinum Poster
Joined: Aug 2015
Posts: 756
Land Lacking in Lakes, IL
There's not a requirement to have a separate one. Ours is incorporated into our Loan Policy. The fewer policies for the board to approve, the better smile
Last edited by MScarn6942; 06/02/17 04:37 PM.
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#2146486 - 09/18/17 06:01 PM Re: Anti-Predatory Lending Policy Reg Warrior
osucpa Offline
Diamond Poster
Joined: May 2011
Posts: 1,406
You have a separate TILA policy?

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