Can a creditor charge a prepayment penalty more than 36 months after the loan consummation under HOEPA?

Under the Home Ownership and Equity Protection Act (HOEPA), which is part of the Truth in Lending Act, there are specific restrictions on prepayment penalties. For loans that fall under HOEPA regulations, a creditor cannot impose a prepayment penalty after the first 36 months of the loan's consummation. Therefore, charging a prepayment penalty more than 36 months after the loan consummation is not permitted.

The correct answer reflects that there are strict limitations on when a creditor can assess these penalties, particularly in relation to the duration after the loan is taken out. The guidelines set forth by HOEPA are specifically designed to protect consumers from unfair lending practices, and allowing a prepayment penalty beyond three years would contravene these protections.

Considering this context, it becomes clear that the assertion that a creditor can charge a prepayment penalty more than 36 months after consummation is incorrect, as HOEPA explicitly prohibits it under the provisions aimed at consumer protection.