At what point must the borrower receive counseling before becoming liable on a HOEPA loan - just after the initial LE or also after receiving the CD?

Also must all borrowers receive counseling or just one?

You must have certification the consumer completed the counseling before you make the loan. If you let them sign the note without the certification then it's too late.

I'm not aware of any allowance for only one of the consumers receiving the counseling.

(iv) Content of certification. The certification of counseling required under paragraph (a)(5)(i) must include:

(A) The name(s) of the consumer(s) who obtained counseling;