Skip to content

HOEPA Consuling Fee-Added as Free Charge?

Answered by: 

Question: 
When the bank is refinancing a loan and the loan is ​subject to ​H​OEPA, the customer has to go to consuling. After the LE is given, the customer comes back and says he cannot afford the $100.00 consuling fee. Can that fee be added as a fee charge or should it be added to the amount requested? If added to the amount requested, does this trigger a right of re​scission?
Answer: 

You are making a HOEPA loan to a consumer that can't afford a $100 fee? I think you need to review your underwriting criteria.

First published on 10/29/2017

Filed under: 
Filed under lending as: 

Banker Store View All

From training, policies, forms, and publications, to office products and occasional gifts, it’s available here:

Banker Store

hot right now

image description

Looking for effective, convenient training on a particular subject?

BOL Learning Connect offers more than 200 courses ON-DEMAND or on CD ROM from AML to Reg Z and every topic in between.

Search Topics