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#465551 - 12/05/05 04:10 PM Another HOEPA question
pjs Offline
10K Club
Joined: Aug 2004
Posts: 10,319
I printed the HOEPA Worksheet off the site and it says in one of the boxes that you provide HOEPA disclosure to all people that have the right to rescind the loan (including non-borrowers, if applicable) etc. I know the ROR is the ownership interest and borrowers'princ dwelling and it could include non- borrowers- but I'm confused with the HOEPA disclosure in relation to non- borrowers-

Also, I've read up on HOEPA and some say "secured by the borrowers' princ dwelling" - now would that also mean that it is like the ROR- that ownership interest applies too.

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Lending Compliance
#465552 - 12/05/05 04:30 PM Re: Another HOEPA question
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 46,844
Bloomington, IN
All persons subject to the ROR will get the HOEPA disclosure because it is consider part of the material disclosures. See footnote 48 in 226.23(a)(3).
The opinions expressed are mine and they are not to be taken as legal advice.

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