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I’m trying to make sure I understand these 3 H’s correctly. I know they all have different thresholds and the property they cover varies. But I’m trying to figure out what the HPCT determines….
For example:
HOEPA – requires disclosure 3 days prior along with may other things
HPML – requires escrows and verfity ablitity to repay
HPCT – ????Does whether a loan is HPCT or not just affect whether the loan qualifies under the “safe harbor” or just the “rebuttable presumption”?
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