RR Joker - it is me who is confused and not understanding my own questions
I have been out of the lending environment for a few years....my lender gave me a copy of a Notice they provide and asked if the new HOEPA Rules replaces this...The notice contains 5 pages.
Page 1: Borrowers Bill of Rights which contains signature lines
Page 2: Consumer Caution and Home Ownerhip Counseling Notice which says "If you obtain this loan, the lender will have a mortgage on your home. You could lose your home, and all money you have invested in it, if you do not meet your obligations under the loan, including making all your payments." There is more information including the counseling hotline phone # and HUD's website, shoping around information, payments contricuting to credit reatings, etc. This page also contains signature lines.
Page 3: List of HUD-Approved Credit Counseling Agencies along with HUD's phone # and website.
Page 4-5: SCRA Notice
The questions I am being asked are:
1. Can the list of HUD-Approved Credit Counseling Agencies on page 3 be replaced with the new "list of 10"?
I thought HUD still required a Notice be given with their phone # and website and the HOEPA List of 10 was in addition to the HUD Notice?
2. Can the Consumer Caution page 2 be omitted - he says he thought this notice applied to LTV's greater than 97% and our max LTV is 96.5%