Does anyone have a sample combined disclosure for HOEPA and the Florida Fair Lending Act?

Altho I haven't studied it extensively, my understanding is that Florida adopted HOEPA as is. Am I missing something? We have extensive worksheets for GA, but just go by HOEPA for our FL branches.

In the Florida Fair Lending Act under Section 4 Required Disclosures for high-cost home loans, A Notice to Borrower is required. Also under Section 3 Prohibited Acts, a lender making a high-cost home loan may include in the loan contract a prepayment fee or penalty for up to the first 36 months after the date of consummation of the loan, if the borrower has also been offered a choice of another product without a prepayment penalty and the borrower has been given, at least 3 business days prior to loan consummation, a written disclosure of the terms of the prepayment fee or penalty by the lender, including the benefit the borrower will receive for accepting the prepayment fee or penalty through either a reduced interest rate on the loan or reduced points or fees.

There is an advance form and notice that has to go in the loan documents, i.e. note. The language is in the Act. We use Rembrandt and those forms are automatically in the loan processing system. You may wish to contact your forms provider or your processing system.

Please indicate which section of the act you are referring to.

Section 4 (1)(a) is the 3-day advance notice verbiage. Section 4(1)(c) is the verbiage required to be on the note of a high cost loan in Florida.

FYI, under the Florida Fair Lending Act, the Department of Banking and Finance was designated as the department responsible for the administration and enforcement of the Act (Section 7(1)(a)). They intend to promulgate rules and may follow the Federal Reserve's approach and allow the notice to be added when needed with a stamp. See the Reg Z commentary Section 226.34(a)(2) Notice to Assignee.