A borrower is refinancing the mortgage on her primary residence. Before the loan closes, the lender informs her that due to the loan's high-cost classification under HOEPA, she is required to attend homeownership counseling. The borrower asks if she can skip the counseling and sign a waiver instead. How should the MLO respond?

The counseling requirement applies only to first-time homebuyers, so the borrower may opt out if she has had a prior mortgage The counseling requirement can be waived if the borrower provides a written statement confirming she understands the loan terms Homeownership counseling is a mandatory borrower protection under HOEPA for high-cost mortgages and cannot be waived by the borrower The borrower may skip counseling only if she has owned a home for more than five years