No. of Recommendations: 2
Of course, you omitted the following part of Dodd Frank:

‘‘(3) PHASED-OUT PENALTIES ON QUALIFIED MORTGAGES.— A qualified mortgage (as defined in subsection (b)(2)) may not contain terms under which a consumer must pay a prepayment penalty for paying all or part of the principal after the loan is consummated in excess of the following limitations:

‘‘(A) During the 1-year period beginning on the date the loan is consummated, the prepayment penalty shall not exceed an amount equal to 3 percent of the outstanding balance on the loan.

‘‘(B) During the 1-year period beginning after the period described in subparagraph (A), the prepayment penalty shall not exceed an amount equal to 2 percent of the outstanding balance on the loan.

‘‘(C) During the 1-year period beginning after the 1- year period described in subparagraph (B), the prepayment penalty shall not exceed an amount equal to 1 percent of the outstanding balance on the loan.

‘‘(D) After the end of the 3-year period beginning on the date the loan is consummated, no prepayment penalty may be imposed on a qualified mortgage.

http://www.dodd-frank-act.us/Dodd_Frank_Act_Text_Section_141...

So certain prepayment penalties are, in fact, still permitted, for the first three years, which is why clause (c), which you quoted states: "(c) Prohibition on certain prepayment penalties" [emphasis added]"

I still have no idea whether the OP's situation fits therein, but your absolutist statement that "Prepayment penalties are no longer allowed under the Dodd-Frank Act" (in post 126600) is simply not correct.

Regards, JAFO
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