POSITION SUMMARY
In the case of HECM loans that are open-end lines of credit, the Anti-Churning Disclosure must be provided concurrently with such other disclosure forms that can be provided in lieu of the GFE under HUD’s RESPA regulations at 24 C.F.R. 3500.7(f), i.e., disclosures required under the Truth in Lending Act (TILA) and Regulation Z. ................
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