In addition, the proposed rule also would implement a Dodd-Frank Act requirement that first-time borrowers receive homeownership counseling before taking out a negatively amortizing loan.
(2) The total points and fees "payable in connection with the transaction" exceed: (a) 5.0% of the total loan amount if the total loan amount is $20,000 or more; or (b) the lesser of 8% of the total loan amount, or $1,000 for a transaction (adjusted for inflation), with a total loan amount of less than $20,000; or
• Restrictions on balloon payments
• Homeownership counseling requirements
Ralph T. Wutscher
McGinnis Tessitore Wutscher LLP
The Loop Center Building
105 W. Madison Street, 18th Floor
Chicago, Illinois 60602
Direct: (312) 551-9320
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