Answer:
HMDA does not require any disclosures similar to HOEPA when the threshold is exceeded.
First published on BankersOnline.com 2/04/08
HMDA Rate Spread - HOEPA Disclosures
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Question:
If the HMDA rate spread exceeds the 3% threshold on a first mortgage, other than reporting it, is the lender obligated to provide any disclosures to the borrower as HOEPA requires?
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