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Test HOEPA at the Time of Loan Estimate?

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Question: 
Should HOEPA be tested at the time of a Loan Estimate? Our system will let us test for it at time of Closing Disclosure, but should it actually test at LE time?
Answer: 

Well, if you don't want a big surprise when you go to close the loan, it is not a bad idea.

First published on 12/23/2018

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