You are correct, as I found a hex viewer and did look at the hex of the file it was FF FE to start with.
And I look at the function you listed LoadFileBOM, and found it would be better for me to use the LoadFileBOMW instead.
The downside to this is it reads it in as a single WString or String, and not a line at a time.
The reason I decided on the LoadFileBOMW is I need to convert it back to a single line of input then take certain bytes out of it, and need to do a select of bytes based upon position in the line.