source:
  type: guide
  id: hud-4000-1-ii-i-final-hecm-decision
  authority: FHA Single Family Housing Policy Handbook 4000.1, Part II — i. Final
    HECM Decision (04/29/2024)
  description: FHA Single Family Housing Policy Handbook 4000.1, Part II — i. Final
    HECM Decision (04/29/2024).
  coverage_tier: operative
obligations:
- id: hud-4000-1-ii-i-final-hecm-decision-full
  canonical_id: hud-4000-1-ii-i-final-hecm-decision-full
  section: FHA Single Family Housing Policy Handbook 4000.1, Part II — i. Final HECM
    Decision (04/29/2024)
  type: do
  tags:
  - regulator-direct
  - fha
  - hud-handbook
  - corpus-expansion
  - tier-operative
  primary_source:
    tier: 1
    authority: FHA Single Family Housing Policy Handbook 4000.1, Part II — i. Final
      HECM Decision (04/29/2024)
    source_class: hud-handbook
    source_url: https://www.hud.gov/hud-partners/single-family-handbook-4000-1
    snapshot_id: 8c03836f77f317e1
    fetched_at: '2026-05-23T00:28:40Z'
    content_hash: sha256:411430f29b13f9b54a2ebb0e6f6e7087ecd2b90d0da22eb0c8c792eaa2d7d0df
    paragraph_quote: 'i. Final HECM Decision (04/29/2024) The underwriter is ultimately
      responsible for making a HECM decision on behalf of their Direct Endorsement
      Mortgagee in compliance with HUD requirements. In making the final HECM decision,
      the underwriter must evaluate the results of the financial assessment and determine
      whether, and under what conditions, the Borrower meets FHA eligibility criteria.
      To determine whether the HECM represents a sustainable solution for the Borrower’s
      financial circumstances, the underwriter must evaluate whether the Borrower
      meets Residual Income, credit history, and property charge history requirements,
      including the use of Extenuating Circumstances and Compensating Factors. The
      Mortgagee must not use FHA’s Technology Open To Approved Lenders (TOTAL) Mortgage
      Scorecard to perform the financial assessment for HECMs. II. ORIGINATION THROUGH
      POST-CLOSING/ENDORSEMENT B. Title II Insured Housing Programs Reverse Mortgages
      5. Performing the Financial Assessment of the Borrower Handbook 4000.1 682 Last
      Revised: 11/26/2025 i. Duty of Care/Due Diligence The underwriter must exercise
      the same level of care that would be used in approving a HECM entirely dependent
      on the Property as security. Compliance with FHA requirements is deemed to be
      the minimum standard of due diligence required in originating and underwriting
      an FHA-insured HECM. ii. Specific Underwriter Responsibilities The underwriter
      must review each HECM as a separate and unique transaction, recognizing that
      there may be multiple factors that demonstrate a Borrower’s ability and willingness
      to meet their financial obligations and comply with the terms of the HECM. The
      underwriter must evaluate the totality of the Borrower’s circumstances and the
      impact of layering risks on the probability that a Borrower will be able to
      meet their financial obligations and comply with the terms of the HECM. As the
      responsible party, the underwriter must: • review appraisal reports, compliance
      inspections, and credit analyses to ensure reasonable conclusions, sound reports,
      and compliance with HUD requirements regardless of who prepared the documentation;
      • determine the acceptability of the appraisal, the inspections, the Borrower’s
      ability to meet their financial obligations and comply with the terms of the
      HECM, and the overall acceptability of the HECM for FHA insurance; • identify
      any inconsistencies in information obtained by the Mortgagee in the course of
      reviewing the Borrower’s application regardless of the materiality of such information
      to the origination and processing of a HECM; and • resolve all inconsistencies
      identified before approving the Borrower’s application, and document the inconsistencies
      and their resolutions of the inconsistencies in the file. The underwriter must
      identify and report any misrepresentations, violations of HUD requirements,
      and fraud to the appropriate party within their organization. iii. Credit and
      Property Charge Payment History The underwriter must determine the creditworthiness
      of the Borrower, which includes analyzing the Borrower’s overall pattern of
      credit behavior and the credit report. See Credit History Review Requirements
      and Property Charge Payment History Review Requirements. The lack of traditional
      credit history or the Borrower’s decision to not use credit may not be used
      as the basis for denying the HECM application. Where the Borrower’s credit and/or
      property charge payment history does not meet the criteria described in Satisfactory
      Credit History and Satisfactory Property Charge Payment History, the Mortgagee
      must either document Extenuating Circumstances, or require a Fully Funded LESA.
      II. ORIGINATION THROUGH POST-CLOSING/ENDORSEMENT B. Title II Insured Housing
      Programs Reverse Mortgages 5. Performing the Financial Assessment of the Borrower
      Handbook 4000.1 683 Last Revised: 11/26/2025 Compensating Factors cannot be
      used to compensate for any derogatory credit. The underwriter must ensure that
      there are no other unpaid obligations incurred in connection with the HECM transaction.
      iv. Monthly Expenses The underwriter must calculate the Borrower’s monthly expenses
      and verify that they have been supported with proper documentation. See Monthly
      Expense Analysis. v. Effective Income The underwriter must review the income
      of a Borrower and verify that it has been supported with the proper documentation.
      See Effective Income Analysis. vi. Residual Income The underwriter must calculate
      the Borrower’s Residual Income and verify that it is supported with proper documentation.
      See Residual Income Analysis. vii. Life Expectancy Property Charges (A) Definitions
      Projected Life Expectancy Property Charges refer to the amount of HECM proceeds
      necessary to pay property taxes, Hazard Insurance, and Flood Insurance, if applicable,
      based on the life expectancy of the youngest Borrower. Life Expectancy Set-Aside
      (LESA) refers to a Set-Aside account that is established for the payment of
      property taxes, Hazard Insurance, and, if applicable, Flood Insurance until
      expended or while the HECM is not in Due and Payable status. LESA funds cannot
      be held in an escrow account. Property Charge Set-Aside refers to a portion
      of a Borrower’s Principal Limit that is designated for payment of Property Charges.
      A Property Charge Set-Aside can result from a Borrower being required to establish
      a Life Expectancy Set-Aside (LESA) or when a Borrower elects to have the Mortgagee
      pay Property Charges on their behalf. Fully Funded Life Expectancy Set-Aside
      (LESA) refers to a portion of the Borrower’s Principal Limit that is designated
      for payment of property taxes, including special assessments levied by municipalities
      or state law, Hazard Insurance, and, if applicable, Flood Insurance for the
      estimated remainder of the Borrower’s life expectancy. With a Fully Funded LESA,
      the Mortgagee makes payments directly to the billing agency. A Borrower can
      voluntarily elect to have a Property Charge Set- Aside created at closing. If
      the Borrower chooses this option, the Property Charge Set-Aside will function
      as though it were a Fully Funded LESA. II. ORIGINATION THROUGH POST-CLOSING/ENDORSEMENT
      B. Title II Insured Housing Programs Reverse Mortgages 5. Performing the Financial
      Assessment of the Borrower Handbook 4000.1 684 Last Revised: 11/26/2025 Partially
      Funded Life Expectancy Set-Aside (LESA) refers to a portion of the Borrower’s
      Principal Limit that is designated for partial payment of property taxes, Hazard
      Insurance, and, if applicable, Flood Insurance for the estimated remainder of
      the Borrower’s life expectancy. With a Partially Funded LESA, the Mortgagee
      makes payments to the Borrower who is responsible for the remaining amounts
      owed and delivering the full payment to the billing agency. (B) Standard The
      underwriter must calculate the Projected Life Expectancy Property Charges for
      all HECMs, regardless of whether a LESA is required or not. The underwriter
      must determine if the Borrower is required to use HECM proceeds to pay for Property
      Charges from a Fully Funded or Partially Funded LESA. Where the Mortgagee will
      pay Property Charges from a Fully Funded LESA, there will be an effective reduction
      in the Borrower’s monthly expenses. Where the amount of Property Charges to
      be paid through the Fully Funded LESA is such that the Borrower will still fall
      significantly short of the Residual Income standard, the approval of a HECM,
      even with a Fully Funded LESA, may not represent a sustainable solution for
      the Borrower’s financial circumstances. (1) Fully Funded LESA Where the Mortgagee
      determines the Borrower has not demonstrated the willingness to meet their financial
      obligations as stated in Satisfactory Credit History and Satisfactory Property
      Charge Payment History and no Extenuating Circumstances can be documented, the
      Mortgagee must, at a minimum, require a Fully Funded LESA. Through the Fully
      Funded LESA the Mortgagee will use HECM proceeds to pay property taxes and insurance
      premiums on behalf of the Borrower. The Borrower remains responsible for timely
      payment of all other Property Charges. (2) Partially Funded LESA Where the Mortgagee
      determines the Borrower has demonstrated the willingness to meet their financial
      obligations as stated in Satisfactory Credit History and Satisfactory Property
      Charge Payment History but does not meet the Residual Income Standard and no
      Compensating Factors can be documented, the Mortgagee must, at a minimum, require
      a Partially Funded LESA. The Mortgagee must determine whether the Partially
      Funded LESA will provide sufficient funds that will result in the Borrower meeting
      the Residual Income standard. If the establishment of the Partially Funded LESA
      will not result in the Borrower meeting the Residual Income standard, then the
      HECM is not a sustainable solution. II. ORIGINATION THROUGH POST-CLOSING/ENDORSEMENT
      B. Title II Insured Housing Programs Reverse Mortgages 5. Performing the Financial
      Assessment of the Borrower Handbook 4000.1 685 Last Revised: 11/26/2025 A Partially
      Funded LESA is not required if the Borrower voluntarily requests a Fully Funded
      LESA. If the amount of the Partially Funded LESA is greater than 75 percent
      of the Projected Life Expectancy Property Charges, a Fully Funded LESA must
      be required. Through the Partially Funded LESA, the Borrower will receive semiannual
      payments from HECM proceeds to pay property taxes and insurance premiums. The
      Borrower remains responsible for timely payment of all Property Charges. (3)
      Voluntary Fully Funded LESA If a Partially or Fully Funded LESA is not required,
      the Borrower may voluntarily request a Fully Funded LESA to pay their property
      taxes and insurance premiums. If a Partially Funded LESA is required, the Borrower
      may voluntarily request a Fully Funded LESA. See Voluntary Property Charge Funding
      Options. (4) Calculation for Projected Life Expectancy Property Charges Mortgagees
      must calculate Projected Life Expectancy Property Charges for each HECM using:
      • 120 percent of the projected sum of: • current property taxes; • Hazard Insurance
      premiums; and • Flood Insurance premiums; • the HECM Expected Rate; • the annual
      MIP rate; and • the life expectancy of the youngest Borrower, with the Borrower
      age rounded up to the nearest whole year if the next birthday is less than 183
      Days after the estimated date of closing. The formula used to calculate Projected
      Life Expectancy Property Charges is: {1.2 × (PC ÷12)} × {(1 + c)m+1 ‒ (1 + c)}
      ÷ {c × (1 + c)m } PC (Property Charges) divided by 12 is the current total monthly
      Property Charge for property taxes, Hazard Insurance, and Flood Insurance. The
      current total monthly Property Charge is multiplied by 1.2 to take into account
      expected increases in property taxes and Hazard and Flood Insurance over the
      life expectancy of the youngest Borrower. c is the monthly compounding rate
      which is defined as the Expected Rate plus the annual MIP rate divided by 12.
      The Expected Rate must be the same rate that is used to determine the Principal
      Limit. II. ORIGINATION THROUGH POST-CLOSING/ENDORSEMENT B. Title II Insured
      Housing Programs Reverse Mortgages 5. Performing the Financial Assessment of
      the Borrower Handbook 4000.1 686 Last Revised: 11/26/2025 m is the Total Annual
      Loan Cost (TALC) life expectancy in total years of the youngest Borrower, with
      the Borrower age rounded up to the nearest whole year if the next birthday is
      less than 183 Days after the estimated date of closing, multiplied by 12 (e.g.,
      for a 74-year-old Borrower whose birthday is more than 183 Days after the estimated
      date of closing, TALC life expectancy is 12 years multiplied by 12 months, which
      equals 144). (5) Calculation for Fully Funded LESA The formula to calculate
      the amount of the Fully Funded LESA is the same as the Projected Life Expectancy
      Property Charges. (6) Calculation for Partially Funded LESA The formula used
      to calculate the amount of a Partially Funded LESA is: (1.2 × MRIS) × {(1 +
      c)m+1 ‒ (1 + c)} ÷ {c × (1 + c)m} Monthly Residual Income Shortfall (MRIS) is
      the difference between the Borrower’s monthly Residual Income and the applicable
      amount of Residual Income for the Borrower’s geographic region and family size,
      based on the Table of Residual Incomes by Region. m is the TALC life expectancy
      in total years of the youngest Borrower, with the Borrower age rounded up to
      the nearest whole year if the next birthday is less than 183 Days after the
      estimated date of closing, multiplied by 12 (e.g., for a 75- year-old Borrower
      whose birthday is less than 183 Days from the estimated date of closing, TALC
      life expectancy equals 132, which is 11 years multiplied by 12 months). c is
      the monthly compounding rate which is defined as the Expected Rate plus the
      annual MIP rate divided by 12. The Expected Rate must be the same rate that
      is used to determine the Principal Limit. The MRIS is multiplied by 1.2 to take
      into account expected increases in property taxes and Hazard and Flood Insurance
      over the life expectancy of the youngest Borrower. (7) Life Expectancy Set-Aside
      Growth Rate All LESAs increase each month at a rate equal to one-twelfth of
      the sum of the Note rate plus the annual MIP rate from the date the loan is
      funded. The LESA amount is determined at origination and the remaining LESA
      balance is adjusted monthly by applying the following formula: 𝐿𝐸𝑆𝐴 𝐵𝑎𝑙𝑎𝑛𝑐𝑒𝑐𝑢𝑟𝑟𝑒𝑛𝑡
      𝑚𝑜𝑛𝑡ℎ= 𝐿𝐸𝑆𝐴 𝐵𝑎𝑙𝑎𝑛𝑐𝑒𝑝𝑟𝑖𝑜𝑟 𝑚𝑜𝑛𝑡ℎ(1 + 𝑑) −𝑇𝑀𝐿𝐷 II. ORIGINATION THROUGH POST-CLOSING/ENDORSEMENT
      B. Title II Insured Housing Programs Reverse Mortgages 5. Performing the Financial
      Assessment of the Borrower Handbook 4000.1 687 Last Revised: 11/26/2025 𝑑= (𝑁𝑜𝑡𝑒
      𝑟𝑎𝑡𝑒+ 𝐴𝑛𝑛𝑢𝑎𝑙 𝑀𝐼𝑃) 12 LESA Balancecurrent month is the LESA balance in the current
      month. LESA Balanceprior month is the LESA balance in the prior month. d is
      the LESA growth rate, which is one-twelfth of the sum of the Note rate plus
      the annual MIP rate. TMLD is the LESA monthly distribution in the current month.
      (8) Fully Funded LESA Information to the Borrower The Mortgagee must inform
      the Borrower of the following: • funds will be used to pay the taxing authority
      or insurance carrier directly; • the Mortgagee is responsible for making timely
      payments to the taxing authority or insurance carrier when funds are sufficient;
      • the projected amount of funds required to cover the LESA charges over the
      estimated life expectancy of the youngest Borrower may be insufficient to cover
      LESA charges for the full length of that specified amount of time; • no funds
      will be available during any applicable Deferral Period for an Eligible NBS;
      and • the Borrower is responsible for the payment of all Property Charges, including
      the LESA charges, over the life of the HECM when funds are insufficient or the
      balance of the LESA is zero. For additional Property Charge Set-Aside requirements,
      see Property Charge Set- Aside in the HECM Servicing and Loss Mitigation section.
      (9) Partially Funded LESA Information to the Borrower The Mortgagee must inform
      the Borrower of the following: • the Borrower will receive semiannual payments
      from the Set-Aside, which must be used to pay the taxing authority and/or insurance
      carrier; • the Borrower is responsible for making timely payments to the taxing
      authority and/or insurance carrier over the life of the HECM; • the projected
      amount of funds required to cover defined Property Charges over the estimated
      life expectancy of the youngest Borrower and the income assumptions used to
      project semiannual distributions to the Borrower may be insufficient to cover
      LESA charges for the full length of that specified amount of time; • no funds
      will be available during any applicable Deferral Period for an Eligible NBS;
      and II. ORIGINATION THROUGH POST-CLOSING/ENDORSEMENT B. Title II Insured Housing
      Programs Reverse Mortgages 5. Performing the Financial Assessment of the Borrower
      Handbook 4000.1 688 Last Revised: 11/26/2025 • the Borrower will no longer receive
      semiannual payments and will continue to be responsible for the payment of all
      Property Charges, including the LESA charges, over the life of the HECM when
      funds are insufficient or the balance of the LESA is zero. For additional Property
      Charge Set-Aside requirements, see Property Charge Set- Aside in the HECM Servicing
      and Loss Mitigation section. (10) Voluntary Property Charge Funding Options
      For adjustable rate HECMs, if the Mortgagee does not require a LESA, the Borrower
      must inform the Mortgagee of the manner in which to pay Property Charges. The
      Borrower may: • elect to have a Fully Funded LESA; • elect to have the Mortgagee
      pay such charges by withholding funds from monthly payments due to the Borrower
      or by charging such funds to a line of credit; or • elect to be responsible
      for independent payment of all Property Charges. For fixed rate HECMs, if the
      Mortgagee does not require a LESA, the Borrower must inform the Mortgagee of
      the manner in which to pay Property Charges. The Borrower may: • elect to have
      a Fully Funded LESA; or • elect to be responsible for independent payment of
      all Property Charges. The Borrower may not cancel any voluntary election property
      charge payment option. If the HECM proceeds are insufficient to pay Property
      Charges, the Borrower must pay all Property Charges, even though the Borrower
      elected payment to be made by the Mortgagee. For additional Property Charge
      Set-Aside requirements, see Property Charge Set-Aside in the HECM Servicing
      and Loss Mitigation section. (C) Required Documentation Mortgagees must provide
      documented reasons for the amount a LESA has been funded and for approving the
      HECM when Borrowers do not meet the standards for Satisfactory Credit History,
      Satisfactory Property Charge Payment History, and Residual Income. viii. Assets
      The underwriter must review the assets of a Borrower and verify that they have
      been supported with the proper documentation. See Asset Requirements. II. ORIGINATION
      THROUGH POST-CLOSING/ENDORSEMENT B. Title II Insured Housing Programs Reverse
      Mortgages 5. Performing the Financial Assessment of the Borrower Handbook 4000.1
      689 Last Revised: 11/26/2025 ix. Verifying Initial Mortgage Insurance Premium
      and Maximum Claim Amount The underwriter must review the IMIP and MCA and verify
      that they have been supported with the proper documentation. x. Servicing Fees
      (A) Definitions Servicing Fee refers to the monthly amount charged by the Mortgagee
      when the cost of servicing is not included in the Note rate. Servicing Fee Set-Aside
      refers to an amount withheld from the HECM proceeds for the payment of the monthly
      servicing fee. (B) Standard The maximum servicing fee that may be charged on
      a fixed rate or an annually adjustable rate HECM is $30 per month. The maximum
      servicing fee that may be charged on a monthly adjustable rate HECM is $35 per
      month. If the Mortgagee chooses to assess a servicing fee, they must establish
      a Servicing Fee Set-Aside based on payment of the monthly servicing fee calculated
      for the life expectancy of the youngest Borrower or Eligible NBS, if applicable.
      Formula for Servicing Fee Sk = FEE × [(1+i)(m+1) – (1+i)] / [i × (1+i)m] Sk
      is the Servicing Fee Set-Aside required in the kth month of the HECM, where
      k at time of loan origination is equal to 1, for future payment of flat monthly
      loan servicing fees from the Borrower’s account, and this amount is constant
      for the entire month. i is the monthly compounding rate calculated as one-twelfth
      of the sum of the mortgage interest rate (Note rate) and the annual MIP rate.
      m is the number of remaining months that the servicing fee could be collected,
      i.e., the remaining term on a tenure mortgage in the kth month of the HECM:
      m = 12 × (100 – Borrower’s Age) – k + 1 Borrower’s Age is the Borrower’s age
      used to calculate the Principal Limit, and FEE is the monthly loan servicing
      fee charged to the Borrower’s account. Where loan servicing charges are included
      in the mortgage interest rate (Note rate) and are paid as a percentage of the
      outstanding loan balance, then FEE is zero, and the calculation of Sk results
      in a zero Set-Aside amount for all months. II. ORIGINATION THROUGH POST-CLOSING/ENDORSEMENT
      B. Title II Insured Housing Programs Reverse Mortgages 5. Performing the Financial
      Assessment of the Borrower Handbook 4000.1 690 Last Revised: 11/26/2025 For
      all other cases, the Servicing Fee Set-Aside, Sk, will decrease as k increases,
      reaching zero for: k = 12 × (100 – Borrower’s Age) xi. Borrower Approval or
      Denial (A) Re-processing The Mortgagee must re-evaluate a HECM when any data
      element of the HECM changes and/or new Borrower information becomes available.
      This includes information that may impact the: • credit history review; • property
      charge payment history review; • monthly expense analysis; • Effective Income
      analysis; and • Residual Income analysis. (B) Documentation of Final HECM Decision
      The underwriter must complete the following documents to evidence their final
      HECM decision. The Mortgagee is responsible for providing well-documented reasons
      for approving the HECM when the Borrower does not meet the standards for Residual
      Income, Satisfactory Credit History, and Satisfactory Property Charge Payment
      History, and all other financial assessment policies. The Mortgagee must complete
      the following documentation requirements. (1) Financial Assessment Worksheet
      The underwriter must record the following items on the HECM Financial Assessment
      Worksheet: • their decision; • any Extenuating Circumstances and Compensating
      Factors; • any approval; and • their Direct Endorsement Identification Number
      and signature. (2) Form HUD-92800.5B, Conditional Commitment Direct Endorsement
      Statement of Appraised Value The underwriter must confirm that form HUD-92800.5B,
      Conditional Commitment Direct Endorsement Statement of Appraised Value, is completed
      as directed in the form instructions. II. ORIGINATION THROUGH POST-CLOSING/ENDORSEMENT
      B. Title II Insured Housing Programs Reverse Mortgages 5. Performing the Financial
      Assessment of the Borrower Handbook 4000.1 691 Last Revised: 11/26/2025 (3)
      Form HUD-92051, Compliance Inspection Report, or Fannie Mae Form 1004D/Freddie
      Mac Form 442, Appraisal Update and/or Completion Report The underwriter must
      confirm that form HUD-92051, Compliance Inspection Report, or Part B of Fannie
      Mae Form 1004D/Freddie Mac Form 442, Appraisal Update and/or Completion Report,
      is completed when required repairs must be completed before closing. (4) Form
      HUD-92900-A, HUD Addendum to Uniform Residential Loan Application The underwriter
      must complete form HUD-92900-A, HUD Addendum to Uniform Residential Loan Application,
      as directed in the form instructions. An authorized officer of the Mortgagee,
      Borrower, Eligible NBS, and the underwriter must execute form HUD-92900-A, as
      indicated in the instructions. (C) Test Case Phase For cases involving Mortgagees
      that receive a Direct Endorsement Program Test Case Phase approval letter from
      FHA, the Mortgagee must complete and submit the processed HECM application and
      Documentation of Final HECM Decision post- closing to FHA for review and issuance
      of a Firm Commitment or Rejection Notice. See Test Case Phase. (D) Conditional
      Approval The underwriter must condition the approval of the Borrower on the
      completion of the final RLARM and form HUD 92900-A at or before closing if the
      underwriter relied on an initial RLARM and form HUD-92900-A in processing the
      HECM. (E) Notification of Borrower of Approval and Term of the Approval The
      Mortgagee must timely notify the Borrower of their approval. The underwriter’s
      approval or the Firm Commitment is valid for the greater of 90 Days or the remaining
      life of the: • Conditional Commitment Direct Endorsement Statement of Appraised
      Value issued by HUD; or • underwriter’s approval date of the Property, indicated
      as the Action Date on form HUD-92800.5B. (F) Borrower and Seller Inspection
      of the HUD-1 Settlement Statement The Mortgagee must prepare the HUD-1 Settlement
      Statement (HUD-1) at least one business day before closing. The Mortgagee must
      provide a copy of the HUD-1 to the Borrower and seller at least one business
      day prior to closing. II. ORIGINATION THROUGH POST-CLOSING/ENDORSEMENT B. Title
      II Insured Housing Programs Reverse Mortgages 6. Closing Handbook 4000.1 692
      Last Revised: 11/26/2025 Mortgagees are responsible for the accuracy of the
      HUD-1. Errors reported by the seller or Borrower must be resolved prior to the
      date of closing. (G) Responsibilities upon Denial When a HECM is denied, the
      Mortgagee must comply with all requirements of the FCRA, and the Equal Credit
      Opportunity Act (ECOA), as implemented by Regulation B (12 CFR Part 1002). 6.
      Closing'
  judgment: false
