Skip to content
BOL Conferences
Thread Options
#912330 - 02/28/08 06:43 PM HOEPA Violation Consequences
BlackHills Offline
Member
Joined: Nov 2007
Posts: 55
What are the consequences if you fail to provide the HOEPA disclosure timely or it does not match the final TIL? I know that the rescission period is extended to 3 years, but is there any monetary fine, or reimbursement to the borrower? Help, I need the answer today!!!!

Return to Top
Lending Compliance
#966798 - 05/30/08 03:12 PM Re: HOEPA Violation Consequences BlackHills
Nameless Offline
100 Club
Joined: Apr 2003
Posts: 249
Chaos
I found this today and had the same question....
_________________________
DON'T PANIC

Return to Top
#971070 - 06/06/08 07:46 PM Re: HOEPA Violation Consequences Nameless
auditor78 Offline
New Poster
Joined: Sep 2006
Posts: 10
Me too, does anyone have an answer???

Return to Top
#971148 - 06/06/08 08:52 PM Re: HOEPA Violation Consequences auditor78
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
HOEPA disclosures are part of the material disclosures. Therefore if they are wrong or not given then you did not provide accurate material disclosures. You would have to recalculate your TIL based on the HOEPA disclosure or refund fees and/or reduce the rate to bring the fees and APR below the threshold.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

Return to Top

Moderator:  Andy_Z