Question concerning points and fees for HOEPA

Posted By: Adam F

Question concerning points and fees for HOEPA - 07/10/14 05:14 PM

Two questions:

Is the cost of life of loan for flood insurance included in the points and fee test for HCMLs and QMs?

If the loan is a HCML, are we prohibited from paying the life of loan fee with loan proceeds?

Thanks in advance for any help you can give me.