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#2224296 - 10/23/19 09:40 PM HOEPA Loan Point and Fees
Nicole Offline
100 Club
Joined: Nov 2018
Posts: 117
Hello, we have a small home purchase loan and test came out that it was HOEPA. I read that there are some exclusion if you meet all requirements of Real Estate Related Fees (1026.32 (b)(1)(iii). Do all fees applies at one time or can we exclude say the appraisal fee only all fees vs. title, our loan fees?

So Basically can we segregate out the appraisal fee from our testing and testing with all other fees?

thank you!

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HOEPA and Homeowner Counseling Rule
#2224504 - 10/26/19 07:42 PM Re: HOEPA Loan Point and Fees Nicole
rlcarey Offline
10K Club
Joined: Jul 2001
Posts: 77,310
Galveston, TX
Would be glad to try and assist, but am having a hard time following your question. Bona-fide third party charges for all items listed in ยง 1026.4(c)(7), unless the charge is unreasonable, the creditor receives direct or indirect compensation in connection with the charge, or the charge is paid to an affiliate of the creditor are not considered in the Section 32 points and fees test.
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