Any upfront PMI disclosed in Section B is a 0% tolerance violation. Other than that, you have a pretty serious good faith violation on the LE for significantly under disclosing the cost of the credit. A one time oops - well figure out what happened, document and train. A pattern or practice, well that is going to be looked at a lot more seriously by the regulators. If this is a secondary market loan, I doubt the investor is going to buy it
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