source:
  type: regulation
  id: usda-hb-3555-16.12
  authority: USDA Technical Handbook HB-1-3555 §16.12 — Ownership Requirements
  description: "USDA HB-1-3555 §16.12 (Ownership Requirements). Gap-fill (verbatim). \n"
obligations:
- id: usda-hb-3555-16.12-0
  canonical_id: usda-hb-3555-16.12-0
  section: USDA HB-1-3555 16.12 — Ownership Requirements
  description: '16.12 Ownership Requirements: NERSHIP REQUIREMENTS A. Lender and Agency Responsibilities After closing,
    the lender must compare the deed of trust or real estate mortgage with the title opinion to assess lien priority,
    assure the collateral is accurately covered, verify the date and time of recording, and ensu…'
  type: do
  tags:
  - regulator-direct
  - gap-fill
  - usda-hb-3555
  - section-complete
  primary_source:
    tier: 1
    authority: USDA Technical Handbook HB-1-3555 §16.12 — Ownership Requirements
    source_class: usda-handbook-hb-1-3555
    source_url: https://www.rd.usda.gov/resources/directives/handbooks
    snapshot_id: 0466acd1ea2d17a4
    fetched_at: '2026-06-18T00:00:00+00:00'
    content_hash: sha256:22ac6f998ff72578e318fca138ebe80fb18ae2fc701eb5936172f1842679a13a
    paragraph_quote: NERSHIP REQUIREMENTS A. Lender and Agency Responsibilities After closing, the lender must compare
      the deed of trust or real estate mortgage with the title opinion to assess lien priority, assure the collateral
      is accurately covered, verify the date and time of recording, and ensure that the loan closing instructions
      have been followed. The Agency does not set policy for survey requirements; however, it is the lender’s responsibility
      to ensure that ownership interest that protects the security property has been obtained after the loan is
      closed. If the borrower defaults on the loan, the lender must be able to foreclose on the property to settle
      the debt. If the lender failed to obtain all required security, the originating lender may be subject to indemnification
      if a loss claim request is made to reflect the lender’s failure to meet the lien requirements. B. Acceptable
      Forms of Ownership The two forms of ownership acceptable to the Agency are fee-simple and secure leasehold.
      1. Fee-Simple Ownership Acceptable fee-simple ownership is evidenced by a fully marketable title with a deed
      HB 1-3555 (03-09-16)
    drafter_attestation: Verbatim from HB-1-3555 §16.12 body (max-gap occurrence), snapshot 0466acd1ea2d17a4; substring-verified.
  judgment: false
- id: usda-hb-3555-16.12-1
  canonical_id: usda-hb-3555-16.12-1
  section: USDA HB-1-3555 16.12 — Ownership Requirements
  description: '16.12 Ownership Requirements: 08-05-25) PN 649 Guidance documents lack the force and effect of law,
    unless expressly authorized by statute or incorporated into a contract. USDA may not cite, use, or rely on any
    guidance that is not available through their guidance portal, except to establish historical facts.…'
  type: do
  tags:
  - regulator-direct
  - gap-fill
  - usda-hb-3555
  - section-complete
  primary_source:
    tier: 1
    authority: USDA Technical Handbook HB-1-3555 §16.12 — Ownership Requirements
    source_class: usda-handbook-hb-1-3555
    source_url: https://www.rd.usda.gov/resources/directives/handbooks
    snapshot_id: 0466acd1ea2d17a4
    fetched_at: '2026-06-18T00:00:00+00:00'
    content_hash: sha256:22ac6f998ff72578e318fca138ebe80fb18ae2fc701eb5936172f1842679a13a
    paragraph_quote: '08-05-25) PN 649 Guidance documents lack the force and effect of law, unless expressly authorized
      by statute or incorporated into a contract. USDA may not cite, use, or rely on any guidance that is not available
      through their guidance portal, except to establish historical facts. vesting a fee-simple interest in the
      property to the borrower. 2. Secure Leasehold Interest Although fee-simple ownership is preferable, the borrower
      may have a secure leasehold interest in the property. Leasehold interests are acceptable when all the following
      conditions are met: x The applicant must be unable to obtain fee-simple title to the property; x The rent
      charged for the lease must not exceed the rate paid for comparable leases; and x The appraisal documents these
      conditions. The lessor must own the fee-simple title. This provision does not apply to a lessor who is a Native
      American possessing a leasehold interest on restricted land. Trust or restricted land must remain in trust
      or restricted status. In these cases, the mortgage, deed of trust, leasehold interest, or other security interest
      must be approved by the Secretary of the Interior. For those loans to Native Americans on restricted or trust
      land, the lender must obtain: x Evidence that the tribe has enacted legally binding and effective foreclosure
      procedures and will enforce those procedures upon notice of default from a lender. x Evidence that the tribe
      has enacted legally binding and effective eviction procedures and will enforce those procedures upon notice
      of default from a lender. x Evidence that the tribe has adopted procedures ensuring that the guaranteed loan
      will always have first lien priority (if applicable) and will be satisfied before all other property debts
      (excepting tribal taxes) OR has adopted legislation requiring the tribe to follow state or local priority
      of lien procedures. x A copy of the tribe’s lease for use on residential land. HB 1-3555 (03-09-16)'
    drafter_attestation: Verbatim from HB-1-3555 §16.12 body (max-gap occurrence), snapshot 0466acd1ea2d17a4; substring-verified.
  judgment: false
- id: usda-hb-3555-16.12-2
  canonical_id: usda-hb-3555-16.12-2
  section: USDA HB-1-3555 16.12 — Ownership Requirements
  description: '16.12 Ownership Requirements: 08-05-25) PN 649 Guidance documents lack the force and effect of law,
    unless expressly authorized by statute or incorporated into a contract. USDA may not cite, use, or rely on any
    guidance that is not available through their guidance portal, except to establish historical facts.…'
  type: do
  tags:
  - regulator-direct
  - gap-fill
  - usda-hb-3555
  - section-complete
  primary_source:
    tier: 1
    authority: USDA Technical Handbook HB-1-3555 §16.12 — Ownership Requirements
    source_class: usda-handbook-hb-1-3555
    source_url: https://www.rd.usda.gov/resources/directives/handbooks
    snapshot_id: 0466acd1ea2d17a4
    fetched_at: '2026-06-18T00:00:00+00:00'
    content_hash: sha256:22ac6f998ff72578e318fca138ebe80fb18ae2fc701eb5936172f1842679a13a
    paragraph_quote: '08-05-25) PN 649 Guidance documents lack the force and effect of law, unless expressly authorized
      by statute or incorporated into a contract. USDA may not cite, use, or rely on any guidance that is not available
      through their guidance portal, except to establish historical facts. x The lender will adhere to the tribe’s
      mortgage, foreclosure and eviction ordinances and the terms of the lease and the lender can only sell the
      leasehold interest to the tribe, the tribally designated housing entity, or another tribal member. The lender
      and RD staff should consult with the tribe to ensure they adhere to the tribe’s ordinances, the terms of the
      lease, and may exercise flexibility as directed by the tribe. The Agency’s Native American Coordinators should
      also be contacted for additional assistance. For all other leasehold interest: x Leasehold estates are an
      accepted practice and readily marketable in the area where the subject property is located. x Neither the
      leasehold nor the fee-simple title may be subject to a prior lien unless the Agency authorizes acceptance
      of the prior lien before loan approval. x The lease must be in writing, recorded, and contain all the following
      provisions: o The lessor’s consent to allow the lender’s mortgage. o The right of the lender to foreclose
      and sell the property without restrictions that adversely affect the market value of the property. o The right
      of the lender to bid at a foreclosure sale or to accept voluntary conveyance of the property in lieu of foreclosure.
      o The right of the lender to occupy, sublet, or sell the property should the leasehold be acquired through
      foreclosure, voluntary conveyance, or abandonment. o The right of the borrower to transfer the leasehold and
      lender mortgage to an eligible transferee who will assume the lender’s debt if the borrower defaults or is
      unable to continue with the lease. HB 1-3555 (03-09-16)'
    drafter_attestation: Verbatim from HB-1-3555 §16.12 body (max-gap occurrence), snapshot 0466acd1ea2d17a4; substring-verified.
  judgment: false
- id: usda-hb-3555-16.12-3
  canonical_id: usda-hb-3555-16.12-3
  section: USDA HB-1-3555 16.12 — Ownership Requirements
  description: '16.12 Ownership Requirements: 08-05-25) PN 649 Guidance documents lack the force and effect of law,
    unless expressly authorized by statute or incorporated into a contract. USDA may not cite, use, or rely on any
    guidance that is not available through their guidance portal, except to establish historical facts.…'
  type: do
  tags:
  - regulator-direct
  - gap-fill
  - usda-hb-3555
  - section-complete
  primary_source:
    tier: 1
    authority: USDA Technical Handbook HB-1-3555 §16.12 — Ownership Requirements
    source_class: usda-handbook-hb-1-3555
    source_url: https://www.rd.usda.gov/resources/directives/handbooks
    snapshot_id: 0466acd1ea2d17a4
    fetched_at: '2026-06-18T00:00:00+00:00'
    content_hash: sha256:22ac6f998ff72578e318fca138ebe80fb18ae2fc701eb5936172f1842679a13a
    paragraph_quote: 08-05-25) PN 649 Guidance documents lack the force and effect of law, unless expressly authorized
      by statute or incorporated into a contract. USDA may not cite, use, or rely on any guidance that is not available
      through their guidance portal, except to establish historical facts. o A negotiated agreement with the lessor
      before the leasehold interest is approved regarding the lender’s obligation to satisfy unpaid rent or other
      charges accrued before or during the time the lender has possession of or title to the leasehold. During negotiations,
      the lender should consider the length of time it will take to foreclose, how much the Agency would be responsible
      for, and when the lender would have to pay. o Fair compensation to the borrower for any part of the property
      taken by condemnation. o The unexpired term of the lease must be at least 150 percent of the term of the mortgage.
      x The language regarding amendments to mortgages with leasehold interests, specified in
    drafter_attestation: Verbatim from HB-1-3555 §16.12 body (max-gap occurrence), snapshot 0466acd1ea2d17a4; substring-verified.
  judgment: false
- id: usda-hb-3555-16.12-4
  canonical_id: usda-hb-3555-16.12-4
  section: USDA HB-1-3555 16.12 — Ownership Requirements
  description: '16.12 Ownership Requirements: 6-A of this Chapter, must be inserted in the mortgage. C. Insurance
    Policy Requirements 1. Hazard Insurance Until loans are paid in full, lenders must ensure that borrowers continuously
    maintain hazard insurance on the collateral to protect against fire and weather- related damag…'
  type: do
  tags:
  - regulator-direct
  - gap-fill
  - usda-hb-3555
  - section-complete
  primary_source:
    tier: 1
    authority: USDA Technical Handbook HB-1-3555 §16.12 — Ownership Requirements
    source_class: usda-handbook-hb-1-3555
    source_url: https://www.rd.usda.gov/resources/directives/handbooks
    snapshot_id: 0466acd1ea2d17a4
    fetched_at: '2026-06-18T00:00:00+00:00'
    content_hash: sha256:22ac6f998ff72578e318fca138ebe80fb18ae2fc701eb5936172f1842679a13a
    paragraph_quote: '6-A of this Chapter, must be inserted in the mortgage. C. Insurance Policy Requirements 1.
      Hazard Insurance Until loans are paid in full, lenders must ensure that borrowers continuously maintain hazard
      insurance on the collateral to protect against fire and weather- related damage. A hazard insurance policy
      must be in force at the time the loan is closed. A policy must document if the dwelling is on a leasehold
      to ensure state laws regarding insurance requirements are met. Lenders should adopt accepted industry standards
      for hazard insurance as noted below: x Hazard insurance providers should have ratings in accordance with the
      most recent Government Sponsored Enterprise (GSE) requirements. x Hazard insurance policies should conform
      to the GSE coverage requirements of “the standard extended coverage endorsement,” which states that a policy
      cannot be accepted that in whole or part excludes wind, hurricane, or catastrophe insurance unless the coverage
      is provided in another policy with HB 1-3555 (03-09-16)'
    drafter_attestation: Verbatim from HB-1-3555 §16.12 body (max-gap occurrence), snapshot 0466acd1ea2d17a4; substring-verified.
  judgment: false
- id: usda-hb-3555-16.12-5
  canonical_id: usda-hb-3555-16.12-5
  section: USDA HB-1-3555 16.12 — Ownership Requirements
  description: '16.12 Ownership Requirements: 08-05-25) PN 649 Guidance documents lack the force and effect of law,
    unless expressly authorized by statute or incorporated into a contract. USDA may not cite, use, or rely on any
    guidance that is not available through their guidance portal, except to establish historical facts.…'
  type: do
  tags:
  - regulator-direct
  - gap-fill
  - usda-hb-3555
  - section-complete
  primary_source:
    tier: 1
    authority: USDA Technical Handbook HB-1-3555 §16.12 — Ownership Requirements
    source_class: usda-handbook-hb-1-3555
    source_url: https://www.rd.usda.gov/resources/directives/handbooks
    snapshot_id: 0466acd1ea2d17a4
    fetched_at: '2026-06-18T00:00:00+00:00'
    content_hash: sha256:22ac6f998ff72578e318fca138ebe80fb18ae2fc701eb5936172f1842679a13a
    paragraph_quote: 08-05-25) PN 649 Guidance documents lack the force and effect of law, unless expressly authorized
      by statute or incorporated into a contract. USDA may not cite, use, or rely on any guidance that is not available
      through their guidance portal, except to establish historical facts. the same coverage limits as the hazard
      policy. Properties should have replacement cost coverage in an amount that is at least equal to the guaranteed
      value of the improvements or the unpaid principal balance. Deductible(s) should not exceed 5% of the total
      coverage amount. When using a high deductible, lenders must be mindful of the applicant’s repayment ability
      and ensure that chosen deductibles are reasonable for the applicant and will not cause undue hardship on the
      borrower. 2. Flood Insurance If a dwelling is in a Special Flood Hazard Area (SFHA) as identified by the FEMA,
      the property must be located within a National Flood Insurance Program (NFIP) participating community and
      the borrower must obtain flood insurance. The lender must ensure the borrower continuously maintains flood
      insurance for the life of the loan and that the policy is in force at the time of loan closing. Flood insurance
      must cover the lesser of the outstanding principal balance of the loan or the maximum amount of coverage allowed
      under NFIP. Unless a higher amount is allowed by state or federal law (which includes FEMA policies), the
      maximum deductible clause for a flood insurance policy should not exceed $10,000. Existing dwellings are eligible
      for the SFHGLP if flood insurance is available. When using a high deductible, lenders must be mindful of the
      applicant’s repayment ability and ensure that chosen deductibles are reasonable for the applicant and will
      not cause undue hardship on the borrower. HB 1-3555 (03-09-16)
    drafter_attestation: Verbatim from HB-1-3555 §16.12 body (max-gap occurrence), snapshot 0466acd1ea2d17a4; substring-verified.
  judgment: false
- id: usda-hb-3555-16.12-6
  canonical_id: usda-hb-3555-16.12-6
  section: USDA HB-1-3555 16.12 — Ownership Requirements
  description: '16.12 Ownership Requirements: 08-05-25) PN 649 Guidance documents lack the force and effect of law,
    unless expressly authorized by statute or incorporated into a contract. USDA may not cite, use, or rely on any
    guidance that is not available through their guidance portal, except to establish historical facts.…'
  type: do
  tags:
  - regulator-direct
  - gap-fill
  - usda-hb-3555
  - section-complete
  primary_source:
    tier: 1
    authority: USDA Technical Handbook HB-1-3555 §16.12 — Ownership Requirements
    source_class: usda-handbook-hb-1-3555
    source_url: https://www.rd.usda.gov/resources/directives/handbooks
    snapshot_id: 0466acd1ea2d17a4
    fetched_at: '2026-06-18T00:00:00+00:00'
    content_hash: sha256:22ac6f998ff72578e318fca138ebe80fb18ae2fc701eb5936172f1842679a13a
    paragraph_quote: 08-05-25) PN 649 Guidance documents lack the force and effect of law, unless expressly authorized
      by statute or incorporated into a contract. USDA may not cite, use, or rely on any guidance that is not available
      through their guidance portal, except to establish historical facts. ATTACHMENT 16-A AMENDMENTS TO MORTGAGES
      WITH LEASEHOLD INTEREST The following paragraphs must be inserted in the mortgage. The first paragraph should
      be placed directly before the legal description of the real estate. “All borrower’s right, title, and interest
      in and to the leasehold estate for a term of years beginning on , 20 , created, executed and established by
      certain Lease dated , 20 , by , Page of Records of said County and State, and any renewals and extensions
      thereof, and all borrower’s right, title, and interest in and to said Lease, covering the following real estate.”
      “Borrower will pay, when due, all rents and all other charges required by said Lease, will comply with all
      other requirements of said Lease, and will not surrender or relinquish any of borrower’s right, title, or
      interest in or to said leasehold estate or under said Lease while this instrument remains in effect.” HB 1-3555
      (03-09-16)
    drafter_attestation: Verbatim from HB-1-3555 §16.12 body (max-gap occurrence), snapshot 0466acd1ea2d17a4; substring-verified.
  judgment: false
- id: usda-hb-3555-16.12-7
  canonical_id: usda-hb-3555-16.12-7
  section: USDA HB-1-3555 16.12 — Ownership Requirements
  description: '16.12 Ownership Requirements: 08-05-25) PN 649 Guidance documents lack the force and effect of law,
    unless expressly authorized by statute or incorporated into a contract. USDA may not cite, use, or rely on any
    guidance that is not available through their guidance portal, except to establish historical facts.…'
  type: do
  tags:
  - regulator-direct
  - gap-fill
  - usda-hb-3555
  - section-complete
  primary_source:
    tier: 1
    authority: USDA Technical Handbook HB-1-3555 §16.12 — Ownership Requirements
    source_class: usda-handbook-hb-1-3555
    source_url: https://www.rd.usda.gov/resources/directives/handbooks
    snapshot_id: 0466acd1ea2d17a4
    fetched_at: '2026-06-18T00:00:00+00:00'
    content_hash: sha256:22ac6f998ff72578e318fca138ebe80fb18ae2fc701eb5936172f1842679a13a
    paragraph_quote: 08-05-25) PN 649 Guidance documents lack the force and effect of law, unless expressly authorized
      by statute or incorporated into a contract. USDA may not cite, use, or rely on any guidance that is not available
      through their guidance portal, except to establish historical facts. ATTACHMENT 16-B Guaranteed Loan Closing
      Reference Guide Question Answer I am trying to access the Loan Note Guarantee from the Single-Family Housing
      Lender Administration List page in the LLC system, but nothing is coming up when I search for the Borrower/Loan.
      Verify you are using the correct Borrower ID number (default choice), Borrower SSN, Name/State, or Lender
      Loan Number and are selecting “Loans” for the “Request Type.” Where can I find instructions for submitting
      the lender loan closing? The “Lender Loan Closing (LLC) Guide” is available in the LINC Training and Resource
      Library, in the “Loan Closing” section. The LINC Training and Resources Library is located at https://www.rd.usda.gov/resources/usda-linc-
      training-resource-library. How do I change the LLC roles of my associates? How do I modify or delete Security
      Administrators? The “SFHGLP System Access and Security Guide” is available in the LINC Training and Resource
      Library, in the “Guaranteed Underwriting System” section, which includes step by step instructions to add,
      modify, or delete existing users. The LINC Training and Resources Library is located at https://www.rd.usda.gov/resources/usda-linc-training-
      resource-library. It has been over 30 days since the loan closed, but we forgot to submit the loan closing
      package. Is it too late to request a Loan Note Guarantee? No. Rural Development will continue to accept complete
      loan closing submissions to assist the lender in obtaining a Loan Note Guarantee. Requests received more than
      30 days after loan closing must include a loan payment history verifying the loan is current, as well as certification
      that all required escrow accounts are current and neither the lender nor another interested party provided
      funds to bring and/or keep the mortgage current to obtain the Loan Note Guarantee. A Loan Note Guarantee will
      not be issued beyond 30 days of the loan closing if the account is in default at the time of the Loan Note
      Guarantee request. HB 1-3555 (03-09-16)
    drafter_attestation: Verbatim from HB-1-3555 §16.12 body (max-gap occurrence), snapshot 0466acd1ea2d17a4; substring-verified.
  judgment: false
- id: usda-hb-3555-16.12-8
  canonical_id: usda-hb-3555-16.12-8
  section: USDA HB-1-3555 16.12 — Ownership Requirements
  description: '16.12 Ownership Requirements: 08-05-25) PN 649 Guidance documents lack the force and effect of law,
    unless expressly authorized by statute or incorporated into a contract. USDA may not cite, use, or rely on any
    guidance that is not available through their guidance portal, except to establish historical facts.…'
  type: do
  tags:
  - regulator-direct
  - gap-fill
  - usda-hb-3555
  - section-complete
  primary_source:
    tier: 1
    authority: USDA Technical Handbook HB-1-3555 §16.12 — Ownership Requirements
    source_class: usda-handbook-hb-1-3555
    source_url: https://www.rd.usda.gov/resources/directives/handbooks
    snapshot_id: 0466acd1ea2d17a4
    fetched_at: '2026-06-18T00:00:00+00:00'
    content_hash: sha256:22ac6f998ff72578e318fca138ebe80fb18ae2fc701eb5936172f1842679a13a
    paragraph_quote: '08-05-25) PN 649 Guidance documents lack the force and effect of law, unless expressly authorized
      by statute or incorporated into a contract. USDA may not cite, use, or rely on any guidance that is not available
      through their guidance portal, except to establish historical facts. Question Answer I did not receive the
      email with a link to the Loan Note Guarantee. Can you resend it to me? The Loan Note Guarantee can be accessed
      by the lender anytime once it is issued by USDA. Lenders can retrieve a copy from GUS by accessing the Application
      Documents Page. The Loan Note Guarantee is also available via the LLC System by following these steps: x Enter
      the correct Borrower ID number (default choice), Borrower SSN, Name/State, or Lender Loan Number. x Select
      “Loans” for the “Request Type.” x Select “Display Documents” from the Action drop- down menu. The status of
      the loan will be set to “closed.” x Select the Borrower ID hyperlink. I think I submitted the loan closing,
      but I am unsure how to confirm. Can you check for me? The easiest way to check on a submitted loan closing
      is to log into GLS and check the “Add/Update Loan Closing” screen. Scroll towards the bottom to see if the
      upfront fee payment information is completed/accepted. For searches completed on the same day the lender submitted
      the LLC, the payment will reflect “pending” until the next day. The Loan Note Guarantee cannot be issued by
      USDA until the payment status changes to “settled.” HB 1-3555 (03-09-16)'
    drafter_attestation: Verbatim from HB-1-3555 §16.12 body (max-gap occurrence), snapshot 0466acd1ea2d17a4; substring-verified.
  judgment: false
- id: usda-hb-3555-16.12-9
  canonical_id: usda-hb-3555-16.12-9
  section: USDA HB-1-3555 16.12 — Ownership Requirements
  description: '16.12 Ownership Requirements: 08-05-25) PN 649 Guidance documents lack the force and effect of law,
    unless expressly authorized by statute or incorporated into a contract. USDA may not cite, use, or rely on any
    guidance that is not available through their guidance portal, except to establish historical facts.…'
  type: do
  tags:
  - regulator-direct
  - gap-fill
  - usda-hb-3555
  - section-complete
  primary_source:
    tier: 1
    authority: USDA Technical Handbook HB-1-3555 §16.12 — Ownership Requirements
    source_class: usda-handbook-hb-1-3555
    source_url: https://www.rd.usda.gov/resources/directives/handbooks
    snapshot_id: 0466acd1ea2d17a4
    fetched_at: '2026-06-18T00:00:00+00:00'
    content_hash: sha256:22ac6f998ff72578e318fca138ebe80fb18ae2fc701eb5936172f1842679a13a
    paragraph_quote: '08-05-25) PN 649 Guidance documents lack the force and effect of law, unless expressly authorized
      by statute or incorporated into a contract. USDA may not cite, use, or rely on any guidance that is not available
      through their guidance portal, except to establish historical facts. Question Answer I submitted the loan
      closing, but I did not receive the loan closing confirmation screen. Our company requires us to print this
      for our files. Is there a way to obtain this? Lenders may obtain a copy of this confirmation by going to the
      Single Family Housing Lender Administration List page in the LLC system. Enter the Borrower ID and ensure
      the “Request Type” is set to “Obligations.” When the correct Borrower has been identified, select the “Action”
      as “Lender Loan Closing Confirmation” and click on the Borrower ID hyperlink. Unauthorized loan funds were
      released to the borrower at closing. How can we correct this? Lenders have two possible solutions: 1. The
      lender may apply the amount of the unauthorized loan funds to the principal loan balance. Documentation of
      the amount applied must be submitted to USDA. 2. Loan fees paid by the applicant(s) with credit cards or other
      short-term loans may not be reimbursed at closing. If the lender is required to reimburse an applicant as
      the result of erroneous preparation of the Loan Estimate, funds may be provided directly to the applicant
      since it represents a penalty due from the lender. HB 1-3555 (03-09-16)'
    drafter_attestation: Verbatim from HB-1-3555 §16.12 body (max-gap occurrence), snapshot 0466acd1ea2d17a4; substring-verified.
  judgment: false
