Topic: High Risk and High-Cost Mortgage Loans
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Does the Home Ownership and Equity Protection Act (HOEPA) apply to FHA Title 1 loans, even though they are government secured?
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We are not aware of any laws or regulations that exempt federally-secured loans from HOEPA’s requirements. In general, the Truth in Lending Act (TILA) applies to loans that are: (1) closed-end credit, (2) secured by the borrower’s principal dwelling, (3) not purchase-money loans, (4) not reverse mortgage loans, and (5) primarily for personal, family, or…