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HOEPA Worksheet Query

Question: 
We have a question concerning HOEPA. On the <a href="http://www.bankersonline.com/tools/lender/hoepa.html">worksheet</a>, it says fees for charges paid by the consumer at or before closing. Is that fees for the service or the actual charge? We are not sure.
Answer: 

I'm not sure what you mean by "fees for the service" vs. "the actual charge". You should list all fees passed on to the consumer that are finance charges (per Reg Z) in rows 21-29. Additionally, list fees passed on to the borrower that are not finance charges yet are paid to the bank or an affiliate of the bank in rows 31-35. Points and Fees are defined in Section 226.32(b)(1) of Regulation Z.

First published on BankersOnline.com 11/26/07

First published on 11/26/2007

Filed under: 
Compliance
Filed under compliance as: 
Fees
HOEPA
IT

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