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#37247 - 10/16/02 01:27 PM HOEPA Disclosure
HR Banker Offline
Diamond Poster
Joined: Oct 2002
Posts: 1,027
I don't find how we show that we informed the customer about HOEPA. Do we keep a signed HOEPA disclosure in the loan file showing that we did disclose this to the customer?

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General Discussion
#37248 - 10/16/02 01:36 PM Re: HOEPA Disclosure
redsfan Offline
Power Poster
redsfan
Joined: Dec 2000
Posts: 3,455
The Pennant Race
The easiest way is to have a customer-signed copy of the disclosure in the file, dated at least 3 days before the closing date of the loan. This is not required by the regulation, however.

Another way to document that the disclosure was given is to build the process into your written procedures. Include the disclosure on your pre-closing checklist, along with the date it was given and the initials of the person who provided or mailed them. Then, include an unisgned copy of the notice in the file.
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